U.S. Nucle

Office of E

Washingt

ar Regulato

nforcement 

on, DC 2055

ry Commissio

5

 A

 AN

 Cal

on 

ALLEG

NNUAL

lendar Y

ATION

 TREN

ear 2012

N PRO

NDS R

2

OGRAM

REPORT
i

CONTENTS 

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

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

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

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

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

Allegation Dispute Resolution Process ............................................................................. 4 

TRENDS IN ALLEGATIONS ......................................................................................................... 5 

National Trends ................................................................................................................. 5 

Reactor Licensee Trends ...................................................................................... 6 

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

Source Trends ....................................................................................................... 8 

Allegation Trends for Selected Reactor Sites ................................................................... 9 

San Onofre Units 2 and 3 .................................................................................... 10 

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

Watts Bar Unit 1 .................................................................................................. 13 

Sequoyah Units 1 and 2 ...................................................................................... 15 

Turkey Point Units 3 and 4 .................................................................................. 16 

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

Allegation Trends for Selected Materials Licensees ....................................................... 18 

Allegation Trends for Selected Vendors .......................................................................... 18 

Shaw Modular Solutions ...................................................................................... 18 

Agreement State Trends ................................................................................................. 19 

CONCLUSIONS .......................................................................................................................... 21 

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

FIGURES 

1 Allegations Received by Calendar Year ............................................................................ 5 

2 Reactor Issues Nationwide 2012 ...................................................................................... 7 

3 Materials Licensee Types Nationwide 2012 ...................................................................... 8 

4 Allegations by Source Category 2012 ............................................................................... 9 

5 San Onofre 2 & 3 Allegations .......................................................................................... 10 

6 Susquehanna 1 & 2 Allegations ...................................................................................... 12 

7 Watts Bar 1 Allegations ................................................................................................... 13 

8 Sequoyah 1 & 2 Allegations ............................................................................................ 15 

9 Turkey Point 3 & 4 Allegations ........................................................................................ 16 

10 Indian Point 2 & 3 Allegations ......................................................................................... 17 

11 Shaw Modular Solutions Allegations ............................................................................... 18 

12 Agreement States ........................................................................................................... 20 
ALLEGATION PROGRAM 2012 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) 2012 involving 

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

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

allegations (Early ADR). This pre-investigation process provides an individual and his or her 

employer (or former employer) the opportunity to resolve an allegation of discrimination through 

mediation rather than fully litigate the discrimination allegation or have the NRC initiate an 

investigation. The NRC pays for, but is not a party to, the voluntary mediation in these 

circumstances. Approximately 35 percent of the CY 2012 mediated discrimination concerns 

reached settlement. 

The total number of allegations1

 received for reactor and materials licensees and vendors 

increased by more than 5 percent in CY 2012, to approximately 600, reversing a declining trend 

in the last 2 years. The increases and decreases in allegation receipt over the last 5 years do 

not appear to be the result of a general industry issue or other external factor. Rather, the 

substantive changes in the number of allegations received were based on a variety of 

plant-specific matters. 

Each allegation can include multiple concerns. Over the last several years, the trend in the total 

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

allegations increased, the number of concerns increased as well). In CY 2012, however, while 

there was an overall increase in allegations received, a decrease in the number of materials 

facility concerns counterbalanced an increase in reactor-related concerns and resulted in the 

total volume of concerns remaining at the CY 2011 level. The largest percentage of concerns 

received nationwide were discrimination concerns, although their number declined slightly from 

the number of discrimination concerns received in CY 2011. These concerns involved workers 

from a variety of functional organizations, although there were concentrations of discrimination 

concerns raised by personnel in both security and maintenance organizations. The majority of 

those involving security were from a variety of sites and utilities in Region I. There is no pattern 

or trend in the maintenance-related discrimination concerns. While the number of 

security-related concerns also remained at a high level, many of the concerns raised involved 

only a small number of reactor sites. Finally, a 10 percent increase in the number of chilling 

effect concerns can be attributed to significant activities—including construction, maintenance, 

and extended outage work—at a limited number of sites. 

For some reactor licensees and one vendor, the NRC received allegations in numbers that 

warranted additional analysis. In preparing this report, the staff reviewed a 5-year history of 

allegations for reactor and materials licensees and vendors to identify adverse trends. The 

analysis focused on allegations that originated from onsite sources to help inform the NRC’s 

review of the safety conscious work environment (SCWE).2

 Because a large volume of 

 

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

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

2

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

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

http://www.nrc.gov/about-nrc/regulatory/allegations/statistics.html. 
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

2 

allegations from onsite sources may be indicative of a SCWE at risk, the staff selected six 

reactor sites and one vendor site with larger numbers of onsite allegations for a more in-depth 

SCWE review: San Onofre Units 2 and 3, Susquehanna Units 1 and 2, Watts Bar Unit 1, 

Sequoyah Units 1 and 2, Turkey Point Units 3 and 4, Indian Point Units 2 and 3, and Chicago 

Bridge & Iron’s Lake Charles, LA, facility (formerly known as Shaw Modular Solutions). This 

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

reactors do not suggest a concern about the environment for raising concerns; however, the 

NRC continues to monitor closely the vendor facility to ensure timely and effective actions are 

taken to address existing SCWE issues. No materials licensees were the subject of allegations 

at a level that warranted additional analysis. 

Finally, in CY 2012, the NRC reviewed the effectiveness of eight Agreement State programs 

and concluded that, with one exception, the Agreement States continue to address concerns 

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

individuals of the outcomes, and protect their identity. The Agreement State program that was 

found to be unsatisfactory in its review and response to allegations, Georgia, is implementing 

recommendations to strengthen its allegation program. The NRC staff is monitoring those 

actions closely.
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

3 

OVERVIEW OF SIGNIFICANT PROGRAM ACTIVITIES

In calendar year (CY) 2012, the U.S. Nuclear Regulatory Commission (NRC) undertook various 

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

developed guidance for the NRC staff considering the issuance of a “chilling effect letter” (CEL). 

NRC Form 3, “Notice to Employees,” was updated in CY 2012 to reflect regional office moves 

and the agency continued its sponsorship of the alternative dispute resolution process for 

discrimination allegations (Early ADR). At the time this report was prepared, approximately 

35 percent of the CY 2012 mediated discrimination concerns resulted in the parties (i.e., 

licensee and concerned individuals) reaching a mutually agreeable settlement. 

Allegation Program Guidance

NRC Chilling Effect Letters

On March 9, 2012, the staff issued enhanced guidance on the consideration and use of CELs. 

A CEL is a regulatory tool that the agency uses to ensure that licensees and other entities 

subject to NRC authority are taking appropriate actions to foster a workplace environment that 

encourages employees to raise safety concerns and to feel free to do so without fear of 

retaliation. The NRC refers to such an environment as a safety conscious work environment 

(SCWE). 

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

number and nature of allegations concerning that site and documented observations based on 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

consider issuing a CEL. For situations involving allegations and other indications of a chilled 

work environment that do not involve a DOL finding of discrimination, but nonetheless may 

warrant the issuance of a CEL, the staff prepared new guidance to ensure the effective and 

consistent use of this tool: Allegation Guidance Memorandum 2012-001, “NRC Chilling Effect 

Letters,” dated March 9, 2012 (Agencywide Documents Access and Management System 

(ADAMS) Accession No. ML12025A055). The guidance does not represent new policies or 

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

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

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

the CEL. No CELs were issued in CY 2012, however, one was issued in CY 2013 shortly 
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

4 

before this report was completed. For more information, see the section entitled, “Allegation 

Trends for Selected Vendors; Shaw Modular Solutions”, later in this report. 

NRC Form 3

The NRC updated publications related to the Allegation Program in CY 2012. The NRC’s 

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

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

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

employee protections against radiation and protections against discrimination for raising safety 

concerns. In February 2012 and again in May 2012, Form 3 was updated to reflect new contact 

information following NRC regional office moves by Regions I and IV. The latest version of 

Form 3 can be found on the NRC’s public Web site at: http://www.nrc.gov/reading-rm/doccollections/forms/. 

Alternative Dispute Resolution Process 

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

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

provides parties additional opportunities to resolve their differences outside the normal 

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

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

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

stem the inherent damage such disputes can inflict on the SCWE more quickly than an 

investigation. At any time, either party can exit the ADR process; whereupon an NRC 

investigation would remain an option if the alleger is still interested in pursuing the discrimination 

matter. More information on Early ADR can be found at: http://www.nrc.gov/aboutnrc/regulatory/enforcement/adr/pre-investigation.html on the NRC’s public Web site. Should 

such an investigation and resulting enforcement panel conclude that enforcement is warranted, 

the NRC and licensee still may engage in what the agency refers to as “post-investigation ADR.” 

Additional information on that process can be found by going to http://www.nrc.gov/aboutnrc/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 of discrimination findings. 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, 17 of the Early ADR offers made by the NRC in 

association with discrimination allegations raised in CY 2012 had resulted in agreements to 

mediate. Of those 17 cases, six (35 percent) mediated discrimination concerns resulted in the 

parties reaching a mutually agreeable settlement. The remaining 11 cases were either still 

being mediated at the time of this report or failed to result in a settlement and the alleger 

requested an NRC investigation. To date, one investigation has been closed as 

unsubstantiated and five are still under investigation. 
ALLEGA

TRENDS

The NRC

agency to

report, th

licensees

into the S

licensees

safety co

activity tw

end-of-cy

wheneve

The staff

shifts in u

has on th

trends. 

National

National 

events, a

useful in 

budget a

assumpt

future ag

Allegatio

Figure 1 

NRC rec

approxim

600 alleg

and that 

had been

in the tot

allegation

CY 2009

allegation

CY 2012

5 percen

In CY 20

total rece

about se

in CY 20

received 

resulted 

to the ide

dropped 

to reacto

and decr

industry 

ATION PROG

S IN ALLEG

C monitors a

o question a

he staff revie

s and vendo

SCWE at a g

s, contractor

oncerns inter

wice a year i

ycle assessm

er allegations

f also condu

users of the 

he workload 

l Trends

trends provi

and industry 

developing 

and planning

ions to supp

gency and 

n Program n

shows that t

eives 

mately 

gations each

although the

n a declining

al number o

ns received 

 through CY

ns increased

 by over 

t. 

09, the total

eived in CY 2

veral reacto

10 and agai

for two reac

in the NRC 

entified SCW

precipitously

or licensees i

reases in alle

issue or othe

GRAM 

ATIONS

allegations to

a licensee ab

ewed a 5-yea

ors. The staf

given facility

r employees

rnally. For p

in support of

ments. In ad

s or inspecti

cts reviews 

Allegation P

in the region

ide general i

efforts to im

port 

needs. 

the 

h year 

ere 

g trend 

of 

from 

Y 2011, 

d in 

 number of a

2008, prima

r facilities an

n in CY 201

ctor facilities

issuing a CE

WE problem 

y in subsequ

in CY 2012, 

egation rece

er external f

 

o discern tre

bout the cau

ar history of 

ff focused on

. Such alleg

, or anonym

power reacto

f the Reacto

ddition, the s

on findings i

to identify na

Program, and

ns and prog

information t

mprove the S

allegations r

rily because

nd one fuel c

1 appear to 

s that experie

EL. As actio

and the rela

uent years. 

material lice

eipt describe

factor, since 

0

200

400

600

800

2008

FIG

Re

 

5 

nds or mark

ses of such 

allegations 

n allegations

gations inclu

mous sources

or facilities, t

or Oversight 

staff may an

indicate that

ational trend

d the effect t

ram offices. 

to the staff a

SCWE at NR

received incr

e of substant

cycle facility

be the resu

enced SCW

ons were imp

ated CEL, the

While there 

ensee-relate

ed above do 

the reasons

8 2009

GURE 1 - ALL

CAL

eactor M

 2012 A

ked increase

changes or 

received for

s with the po

ude those su

s that indicat

the staff ana

Process (RO

alyze a part

t such an an

ds for reacto

that the imp

 The followi

about the eff

RC-licensed f

reased by a

tive increase

. The decre

lt of large re

E problems 

plemented a

e number of

was an incr

ed allegation

not appear t

s for the sub

2010 201

LEGATIONS 

LENDAR YEA

Materials

ANNUAL TR

s that might 

trends. In p

r reactor and

otential to pro

bmitted by c

te an unwilli

alyzes recent

OP) mid-cyc

icular site or

nalysis is war

r and materi

lementation 

ing section d

fect of extern

facilities. Th

bout 10 perc

es in allegati

eases in alleg

eductions in a

in previous y

at these facili

f allegations 

rease in alle

s declined. 

to be the res

stantive cha

11 2012

RECEIVED B

AR

Agreement 

RENDS REP

prompt the 

preparing thi

d materials 

ovide insigh

current or fo

ngness to ra

t allegation 

cle and 

r licensee 

rranted. 

ials allegatio

of the progr

discusses th

nal factors, p

hey can be 

cent over the

ons received

gations rece

allegations 

years, which

ities in respo

received 

gations relat

The increas

sult of a gen

anges in the 

BY 

State

PORT 

is 

ts 

rmer 

aise 

ons, 

ram 

ese 

plant 

e

d

eived 

h

onse 

ted 

ses 

eral 
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

6 

number of allegations received about these facilities were plant-specific and varied 

(e.g., significant outage activity, construction activity, security issues, work environment issues, 

or process/program changes). 

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

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

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

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

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

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

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

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

Agreement State. 

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

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

the last several years, the trend in the total number of concerns has paralleled the trend in total 

allegations (e.g., if the number of allegations increased, the number of concerns increased as 

well). In CY 2012, although there was an overall increase in allegations received, the total 

volume of allegation concerns received remained at the CY 2011 level. While there was a 

decrease in the number of materials facility concerns, the number of reactor concerns increased 

nationally and in two of the four regional offices. Region IV, in particular, experienced an 

increase of over 30 percent in the number of reactor concerns received. 

 

Reactor Licensee Trends

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

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

approximately 80 percent of the issues received nationwide in CY 2012.3

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

discrimination concerns, although their number declined slightly from the number of 

discrimination concerns received in CY 2011. A review of all discrimination concerns received 

in CY 2012 found that claims were made by approximately 30 percent more licensee employees 

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

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

Region III. These concerns involved workers from a variety of functional organizations, 

although there were concentrations of discrimination concerns raised by personnel in both 

security and maintenance organizations. The majority of those involving security were from a 

variety of sites and utilities in Region I. There is no pattern or trend in the maintenance-related 

discrimination concerns. 

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

concerns raised involved only a small number of reactor sites. The majority of security-related 

allegation concerns were received in CY 2012 from licensee employees and primarily from sites 

 

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

20 percent of the issues received. These areas include emergency preparedness, quality assurance, 

fatigue/overtime, mechanical, electrical, construction, civil/structural, fire protection, Employee Concerns 

Programs, licensing, environmental, in-service testing, chemistry, environmental qualifications, heating, 

ventilation, and air conditioning, safeguards, criticality safety, procurement, nondestructive evaluation, and 

instrumentation and control. 
ALLEGA

in Region

adequac

The total

The NRC

interactio

to the em

attributed

work, at a

concerns

There wa

NRC def

action or

allegation

area. 

Other tre

action co

include le

to be rela

ATION PROG

n I. There w

y, discrimina

 number of c

C uses the te

on, decision,

mployer or to

d to significa

a limited num

s in the oper

as a slight in

fines “wrongd

r a violation r

n concerns i

ends noted in

oncerns that 

ess significa

ated to any p

W

Fitness for 

6%

En

Opera

4%

Aut

Trainin

4

S

Discrimina

Corrective 

Wrongdoin

Operations

Safety Cult

GRAM 

were concent

ation, and se

chilling effec

erm “chilling 

 or policy ch

o the NRC is

ant activities,

mber of sites

rations, engin

ncrease in th

doing” as th

resulting from

involved a n

nclude cons

can be attrib

ant increases

particular fac

Wrongdoing

7%

Duty

gineering

5%

ations

%

Access 

thorization

4%

ng/Quals

4%

Safety Culture

4%

ation

Action

ng

s

ture

FIGURE 2 - R

 

trations of co

ecurity equip

ct concerns i

effect” to de

hange results

 being supp

, including co

s. In genera

neering, qua

he volume of

e willful viola

m careless d

umber of dis

iderable incr

buted to site

s in health p

cility, work g

Maintena

7%

e Falsific

4%

Security

Health Ph

Fitness fo

Access A

Falsificati

REACTOR IS

 

7 

oncerns reg

pment issues

increased a 

escribe a con

s in a percep

ressed or is 

onstruction, 

al, there wer

ality assuran

f wrongdoing

ation of regu

disregard of 

sciplines; the

reases in the

es with signif

hysics and e

roup, or eve

Hea ance

cation

%

hysics

or Duty

Authorization

ion

SSUES NATIO

 2012 A

arding secu

s. 

little over 10

ndition that o

ption that the

discouraged

maintenanc

e concentra

nce, and mai

g concerns r

ulatory requi

regulatory r

e largest vol

e areas of m

ficant outage

engineering

ent. 

Discri

1

S

Ch

alth Physics

9%

Emergency 

Preparedness

3%

Chilling 

Mainten

Enginee

Training

Emergen

ONWIDE 201

ANNUAL TR

rity plan and

0 percent in 

occurs when

e raising of s

d. The incre

ce, and exten

tions of chill

intenance fu

received in C

rements thro

requirements

ume involve

maintenance 

e activities. 

concerns th

mination

13%

Security

11%

hilling Effect

10%

Corrective 

Action

9%

s

Effect

ance

ering

g/Quals

ncy Preparedn

2

RENDS REP

d procedure 

CY 2012. 

n an event, 

safety conce

ease can be

nded outage

ing effect 

unctional are

CY 2012. Th

ough deliber

s. Wrongdo

ed the securi

and correct

Trends also

at don’t app

ness

PORT 

erns 

e

eas. 

he 

rate 

ing 

ity 

ive 

o

pear 
ALLEGA

Materials

A compa

there are

To provid

allegation

approxim

The NRC

CY 2011

constitute

fewer fue

allegation

allegation

were rec

reactors 

Source T

Figure 4 

allegation

remained

employee

 

4 Th

w

ca

an

5

 Th

in

Fue

Dec

Exe

ATION PROG

s Licensee T

arison of the 

e many differ

de insights in

ns, Figure 3 

mately 80 pe

C received 1

. Since CY 

ed the highe

el facility-rela

ns related to

ns received 

eived in CY 

and materia

Trends

provides a b

ns received 

d consistent 

es) and cont

 

he agency rece

which represent

asks, exempt d

nd research rea

he NRC receiv

nclude the news

Decommi

Materi

10%

Decomm

Rea

7

Radio

8

Exem

FIG

el Facililty

commissioni

empt Distribu

GRAM 

Trends

types of issu

rent types of

nto areas in 

depicts the 

rcent of alleg

2 percent fe

2004, the nu

est percentag

ated allegati

o nuclear gau

in CY 2012.

2012 than in

als facilities, 

breakdown o

in CY 2012.

from CY 20

tractors (or f

 

eived few conc

 the remaining 

distribution, gen

actors, transpo

ved few concern

s media and sp

Me

1

ssion. 

als

%

mission. 

actor

%

graphy

8%

mpt Distributio

4%

GURE 3 - MA

ng Materials

ution

 

ues received

f materials li

which the N

nine types o

gation conce

ewer allegatio

umber of alle

ge (30 perce

ons were re

uge licensee

. However, 4

n CY 2011. 

and radiogra

of 99 percen

.

5

 The data 

08 to CY 20

former contr

cerns about the

20 percent of 

neral licensee, 

ortation, waste 

ns from the 1 p

pecial interest g

edical

0%

on

Re

Dev

ATERIALS L

Nuclear 

s Decomm

Researc

 

8 

d does not p

censees and

NRC focused

of materials 

erns that the

ons in CY 20

egations rela

ent to 50 per

ceived in CY

es were the 

40 percent f

Allegation r

aphy license

nt of the sour

indicate that

012. That is,

ractors) cont

e materials licen

the issues rece

irradiators, nuc

disposal, and o

percent of sour

groups. 

Nucl

esearch & 

velopment

4%

LICENSEE T

Gauges

missioning R

ch & Develop

 2012 A

produce mea

d the activiti

d its attention

licensees th

e NRC receiv

012 in the m

ated to fuel 

rcent) of suc

Y 2012 than 

second high

fewer nuclea

receipt rates

ees also dro

rces for reac

t the distribu

, employees

tinue to be th

nsee types tha

eived. These l

clear pharmaci

other types. 

rces not depicte

Fuel F

48

lear Gauges

11%

Nuclear 

TYPES NAT

M

Reactor R

pment N

ANNUAL TR

aningful resu

es they perf

n on materia

hat accounte

ved nationw

materials are

cycle facilitie

ch allegation

in CY 2011

hest percent

ar gauge-rela

s for both dec

pped in CY 

ctors and ma

ution of sourc

s of licensees

he primary s

t are not depic

icensee types 

ies, special nuc

ed in Figure 4. 

Facililty

8%

Pharmacies

3%

TIONWIDE 2

Medical

Radiography

Nuclear Pha

RENDS REP

ults because

form vary gre

als-related 

ed for 

wide.4

a than in 

es has 

ns; however, 

. As in CY 2

age of mate

ated allegati

commission

2012. 

aterials 

ce categorie

s (or former 

sources of 

cted in Figure 3

include academ

clear material, 

 These source

2012

y

rmacies

PORT 

e

eatly. 

2011, 

erials 

ions 

ing 

es 

3, 

mic, 

test 

es 
ALLEGA

allegation

14 perce

previous 

approxim

In consid

insights i

licensee 

these so

Two of th

designate

deliberat

by the NR

licensee 

to the NR

that the e

Allegatio

Trending

aggregat

appendix

received 

Decembe

be indica

employee

this analy

Because

the staff 

allegation

L

L

ATION PROG

ns. For CY 

ent, while the

year. The n

mately 18 pe

dering those 

nto the SCW

or contracto

urces since 

he source ca

es an NRC s

ely or as a r

RC Office of

representat

RC. The age

evaluation p

on Trends f

g the number

te, is one me

x to this repo

the listed al

er 2012 and

ative of the h

es, current o

ysis, the NR

e a large volu

conducted a

ns. In previo

A

FI

Licensee Em

Licensee Ide

GRAM 

2012, the nu

e number of 

number of pe

rcent compa

allegation s

WE at a give

or employees

CY 2008 ha

ategories de

staff membe

result of care

f Investigatio

ive, acting in

ency staff as

rogress of th

for Selected

r and nature

ethod the NR

ort provides 

llegations du

 included on

health of the 

or former con

RC assumed 

ume of alleg

a more in-de

ous years, th

Con

Em

Anonymous

9%

Licensee 

Identified

9%

Private

9

GURE 4 - A

mployee

entified

 

umber of alle

allegations r

ersons wish

ared to CY 2

sources men

n facility (i.e

s or by anon

as notably re

serve some 

er who suspe

eless disrega

ons. The so

n his or her o

ssigns an all

he alleged w

d Reactor S

e of allegatio

RC staff use

statistics on

uring the 5-y

nly allegation

SCWE). On

ntractor emp

that anonym

ations from 

epth SCWE r

he sites rece

ntractor 

mployee

26%

e Citizen

9%

ALLEGATIO

Contra

Private

 

9 

egations rais

raised by co

ing to remai

2011. 

tioned previ

e., allegation

nymous sour

emained con

explanation

ects that a re

ard, thus pro

urce catego

official capac

egation proc

wrongdoing is

ites

ns for specif

es to monitor

 allegations 

year period b

ns received f

nsite source

ployees, or a

mous allegat

onsite sourc

review of ce

eiving additio

N

NS BY SOU

actor Emplo

e Citizen

 2012 A

sed by licens

ontractors de

n anonymou

ously that ha

s submitted 

rces), the pe

nsistent arou

n. The sourc

egulatory req

ompting the 

ry “Licensee

city, has rep

cess tracking

ssue may be

fic reactor si

r the SCWE 

for all opera

between Jan

from onsite s

es include cu

anonymous 

tions came f

ces may be i

rtain sites w

onal review w

Li

Em

NRC Staff

5%

URCE CATE

oyee A

N

ANNUAL TR

see employe

eclined 8 per

us declined i

ave the pote

by current o

ercentage of

nd 75 perce

ce category 

quirement h

initiation of a

e Identified” 

ported poten

g number to

e tracked. 

ites, individu

at reactor si

ating reactor

nuary 2008 a

sources (i.e

urrent or form

allegers. Fo

from onsite p

indicative of

with larger nu

were determ

censee 

mployee

42%

EGORY 2012

Anonymous

NRC Staff

RENDS REP

ees increase

rcent from th

in CY 2012 

ential to prov

or former 

f allegations 

ent. 

“NRC Staff” 

as been vio

an investiga

denotes tha

tial wrongdo

o such items 

ually and in t

ites. The 

r sites. The 

and 

., those that 

mer licensee

or the purpos

personnel. 

f a SCWE at

umbers of on

mined by a 

2

s

PORT 

ed by 

he 

by 

vide 

from 

lated 

tion 

at a 

oing 

so 

the 

NRC 

may 

e

se of 

 risk, 

nsite 
ALLEGA

simple al

sites ove

more in-d

and cont

the data 

Based on

the follow

both reac

evaluatio

• 1 

vo

• 2 

vo

• 3 

vo

The staff

times of s

For CY 2

Units 2 a

and 2 (19

operating

analysis 

San Ono

During 20

3 at a hig

in CY 20

overall ra

from the 

CY 2010

NRC ass

SCWE a

2 and 3 p

issuance

letter in e

analysis 

matter of

received 

indicates

three fun

(mainten

and engi

being foc

Units 2 a

issues) li

ATION PROG

lgorithm bas

er the calend

depth SCWE

ractors (suc

helps to ens

n an NRC O

wing criteria 

ctor and mat

on: 

- unit reacto

olume great

- unit reacto

olume great

- unit reacto

olume great

f recognizes

significant s

2012, the me

and 3 (28), S

9), Turkey P

g reactor site

of the SCW

ofre Units 2 a

012, NRC re

gher rate tha

11), althoug

ate has decr

CY 2009 an

 time frame,

sessment of 

t San Onofre

prompted the

e of a chilling

early 2010. 

of the subje

f the allegati

in CY 2012 

s concentrati

nctional area

ance, opera

neering) wit

cused in the 

and 3 (Unit 2

kely contribu

GRAM 

sed on the m

dar year (tha

E review). H

ch as 3-unit r

sure that tho

Office of Rese

for CY 2012

terials faciliti

or sites (or a

er than 2.25

or sites (or a

er than 3 tim

or sites (or a

er than 4.5 t

, and takes 

ite activity, t

edian numbe

Susquehanna

Point Units 3 

es that met t

E at each of

and 3

eceived alleg

an the previo

gh the 

reased 

nd 

, when 

the 

e

e

g effect 

An 

ct 

ons 

ions in 

as 

ations, 

h 50 percen

maintenanc

2 refueling ou

uted to the a

 

median numb

t is, sites ex

However, bec

reactor sites

ose sites are

earch study,

2 to consider

ies, and dete

any site with 

5 times the m

any site with 

mes the med

any site with 

times the me

into conside

he site popu

er of allegatio

a Units 1 an

and 4 (17), 

the above cr

f these sites

gations from

ous year (28

nt of the alle

ce area. Sub

utage, vesse

areas of con

0

10

20

30

40

50

60

FIGU

S

 

10 

ber of allega

xceeding thre

cause sites 

) typically ge

 not disprop

, the Agency

r the varying

ermine whic

fewer than 8

median 

800 to 1,10

dian 

more than 1

edian 

eration when

ulation may i

ons per ope

d 2 (21), Wa

and Indian P

riteria. The s

. 

m onsite sour

 allegations 

egations rece

bstantive ou

el head repla

centration. 

2008 2009

URE 5 - SAN

Substantiated

 2012 A

tions receive

ee times the

with a large

enerate mor

portionally ch

y Allegations

g workforce s

ch sites warra

800 persons

0 persons) w

1,100 person

 applying the

increase sub

rating reacto

atts Bar Unit

Point Units 2

sections bel

rces concern

in CY 2012,

eived from o

tage activity

acement, ste

Allegations 

9 2010

N ONOFRE 2

Closed

ANNUAL TR

ed at operat

e median we

r population 

re allegations

hosen for fur

s Advisor ad

size at differ

anted furthe

s) with an on

with an onsit

ns) with an o

e above crite

bstantially. 

or site was 3

t 1 (21), Seq

2 and 3 (17)

ow discuss t

ning San On

, compared t

onsite source

y in CY 2012

eam generat

were receive

2011 2012

2 & 3 ALLEG

Receive

RENDS REP

ing reactors

re chosen fo

of employee

s, normalizin

rther analysis

opted the us

rent sites, fo

er SCWE 

nsite allegati

te allegation

onsite allega

eria, that du

3.5. San On

quoyah Units

, are the six

the staff’s 

nofre Units 2

to 23 allegat

es in CY 201

2 at San Ono

tor tube leak

ed on a 

GATIONS

ed

PORT 

or a 

es 

ng 

s. 

se of 

r 

on 

ation 

ring 

nofre 

s 1 

 and 

tions 

12 

ofre 

k
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

11 

consistent basis from January through September 2012, with a more concentrated receipt rate 

in the last quarter of CY 2012, after the licensee’s initiation of a staff reduction in force (the 

Business Transformation process) during that time frame which, when completed in CY 2013, is 

expected to reduce the site population by over 700 workers. Allegations were received in 

CY 2012 primarily from current and former licensee employees, rather than contractors. There 

was one anonymous allegation. 

Nine chilling effect concerns were raised in CY 2012 from various onsite sources. This 

represents a decrease in the amount of chilling effect concerns received by the NRC compared 

to the numbers received in CY 2009, CY 2010, and CY 2011, when over 15 concerns of this 

type were received each year. The chilling effect concerns received in CY 2012 were spread 

among multiple plant departments, and two were related to isolated incidents that affected only 

the individual who filed the concern. Chilling effect concerns received early in CY 2012 were 

closed as unsubstantiated based on the results of the 2011 NRC Problem Identification and 

Resolution (PI&R) inspection and on the licensee's most recent SCWE survey results, which 

found that the overall work environment at San Onofre 2 and 3 was continuing to improve as a 

result of actions taken since the issuance of the chilling effect letter in March 2010. A number of 

the chilling effect concerns received later in CY 2012 were related to the recent site reduction in 

force. 

The number of discrimination concerns received by the NRC related to the San Onofre site from 

CY 2008 through CY 2012 (45) is the highest in the industry in that time frame. However, to 

date, none of the discrimination concerns have been substantiated. There were 

10 discrimination concerns received in CY 2012, an increase from CY 2011, when seven 

discrimination concerns were received. 

On September 6, 2011, the NRC followup actions related to the chilling effect letter issued in 

March 2010 were closed (ADAMS Accession No. ML112490114). To reach this determination, 

the NRC reviewed the licensee’s root cause evaluations and planned corrective actions to 

improve the SCWE, which applied performance metrics to measure progress in the SCWE area. 

In addition to monitoring the licensee’s corrective actions and performance against the 

established metrics, the NRC conducted multiple inspections in 2010 and 2011 to obtain input 

about the status of the SCWE at the San Onofre Nuclear Generating Station, the most recent 

being focused PI&R team inspections in January 2011 and May 2011 (ADAMS Accession No. 

ML111250473). During these inspections, over 500 plant employees were interviewed either 

individually or in a focus group setting. As a result, the NRC concluded that the licensee had 

made reasonable progress in addressing the SCWE problem, had implemented corrective 

actions that were effective in addressing underlying issues, and was committed to continued 

improvement in this area. 

The San Onofre Employee Concerns Program (ECP) received fewer nuclear safety/quality 

concerns and SCWE-related concerns in 2012 compared to 2011, and considerably less than 

the number received in 2010 (when the NRC chilling effect letter was issued). ECP received 

more concerns in the first quarter of 2012, when extended outage activity was occurring onsite, 

compared to the remainder of the year. After the initiation of the company reduction in force 

effort in August 2012, ECP received few concerns related to the implementation of the first 

phase of the process (voluntary resignations). Later in 2012, ECP received a concentration of 

concerns from site departments that were being more significantly affected by later phases of 

the reduction in force. After the initiation of the Business Transformation process, the licensee 

established “SCWE Advocates” in the major work groups at the site. The SCWE Advocates 

pulse their department for reactions to the reduction in force and any other SCWE-related 
ALLEGA

matters. 

proposed

In respon

survey in

of the foc

manager

as part o

In summ

concerns

of conce

San Ono

and 3 an

CY 2010

In 2012, 

to previo

Transform

be limitin

remainin

likelihood

problema

The NRC

inspectio

to monito

implemen

schedule

Susqueh

Although

Susqueh

(21), the 

problem 

NRC reg

A review 

receipt, a

and issue

the chillin

CY 2012

problem 

specific d

majority o

involved 

managem

the subje

allegation

ATION PROG

 Meetings a

d efforts in re

nse to the m

n April 2012,

cus organiza

r was assign

of the first ph

ary, while bo

s respectivel

rns received

ofre 2 and 3. 

d the implem

 time frame,

however, th

us years. W

mation proce

ng the numbe

g phases of

d of increasi

atic. 

C is maintain

on activities t

or events an

ntation of th

ed to be com

hanna Units 

h the number

hanna Units 

nature of th

at the site. 

arding activ

of the subje

and variabilit

es involved d

ng effect con

 were not in

at the facility

department o

of the chillin

company po

ment behavi

ect matter of

n concerns r

GRAM 

re held wee

esponse. 

most recent s

 with attentio

ations showe

ned in late 20

hase of the re

oth the NRC

y at a stead

d do not prov

 Because o

mentation of

, chilled work

ere was a d

With regard to

ess), interna

er of concer

the staff red

ng the volum

ning its overs

to ensure tha

d activities t

e remaining 

mpleted by Ju

1 and 2

r of allegatio

1 and 2 in C

e allegations

However, it 

ities at Susq

ect matter, ti

ty of departm

demonstrate

ncerns recei

dicative of a

y or a trend 

or discipline

g effect con

olicy issues 

ors. An ana

f the technica

received in 

 

kly with site 

site SCWE s

on to certain

ed improvem

012, after the

eduction in f

C and the lice

y and comp

vide evidenc

of the recent 

f multiple res

k environme

ecreased am

o the license

al communic

ns being rec

duction, whic

me of concer

sight of the S

at the licens

that could ne

phases of t

une 2013). 

ons received

CY 2012 (22)

s received d

is noted tha

quehanna at

me of 

ments 

ed that 

ved in 

a SCWE 

in a 

. The 

cerns 

and 

alysis of 

al 

 

12 

senior mana

urvey in 201

n focus organ

ment in SCW

e previous E

force. 

ensee contin

aratively hig

ce of a re-de

history of w

sponse actio

ent concerns

mount of chi

ee’s recently

cation and su

ceived by the

ch will includ

rns provided

SCWE at Sa

see continue

egatively imp

he Business

 by the NRC

) was similar

does not app

at chilling effe

t a relatively

0

5

10

15

20

25

30

35

2008

FIG

AL

Subst

 2012 A

agement to 

11, the licens

nizations. T

WE. It is also

ECP manage

nued to rece

gh rate in 20

eveloping wo

ork environm

ons and man

s continue to

lling effect c

y initiated red

upport efforts

e NRC abou

de employee

d to the NRC

an Onofre 2 

s its efforts t

pact the SCW

s Transforma

C from onsite

r to the num

pear to indica

ect concerns

high rate in 

2009 2

GURE 6 - SU

LLEGATIONS

tantiated

ANNUAL TR

discuss issu

see conduct

The licensee 

o noted that 

er took volun

eive allegatio

12, the num

ork environm

ment issues 

nagement ch

o be received

concerns rec

duction in fo

s by the lice

ut this action

e layoffs, will

C if implemen

and 3 throug

to promote t

WE (in partic

ation staff re

e sources at

ber received

ate a work e

s continued 

CY 2012. 

010 2011

USQUEHANN

S

Closed

RENDS REP

ues and 

ted a followu

indicated th

a new ECP 

ntary resigna

ons and ECP

ber and natu

ment problem

at San Ono

hanges since

d by the NRC

ceived comp

orce (Busines

nsee appea

. However, 

l have a high

ntation is 

gh normal 

the SCWE a

cular, the 

eduction 

t

d in CY 2011

environment 

to be raised

2012

NA 1 & 2 

Received

PORT 

up 

hat all 

ation 

P

ure 

m at 

fre 2 

e the 

C. 

ared 

ss 

ar to 

the 

her 

and 

1

 to 
ALLEGA

CY 2012

or conce

The num

compare

CY 2009

unable to

remain o

The lates

willingne

were awa

inspectio

provided 

workforce

The Susq

concerns

the numb

outage w

policy ch

along wit

anonymo

corrective

A site sa

March 20

more rec

being wr

ECP has

manager

In summ

sources d

Susqueh

through n

recent m

Watts Ba

The num

the NRC 

Watts Ba

increased

received 

indicates

raised inv

resulted 

an event 

the licens

fitness-fo

ATION PROG

 regarding S

rn type. 

mber of discri

ed to previou

). Of the 24

o substantiat

open. 

st PI&R insp

ss of site wo

are of the va

on found that

the licensee

e. 

quehanna 1 

s than CY 20

ber of conce

was more tha

anges in ea

th managem

ous concerns

e action prog

fety culture s

011 identifie

cently in earl

itten). A new

s received fe

r. However, 

ary, while th

do not indica

hanna 1 and 

normal inspe

anagement 

ar Unit 1

mber of allega

from onsite

ar Unit 1 in C

d significant

in CY 2011 

s that a third 

volved Unit 

from employ

in February

see’s implem

or-duty (FFD

GRAM 

Susquehann

imination co

s years (six 

4 raised durin

te any to dat

pection at Su

orkers to rais

arious avenu

t the results 

e with good 

and 2 ECP 

011). While 

erns received

an at other o

rly 2012 rela

ment changes

s were recei

gram area, w

survey cond

d concerns r

y 2013, but 

w operations

ewer concern

licensed op

he number a

ate a work e

2, some are

ection activit

changes an

ations receiv

 sources reg

CY 2012 (21

tly from the n

(5). Analys

of the conce

Operations a

yee percepti

y 2012 conce

mentation of

D) program. 

 

a also does 

ncerns rece

in CY 2012

ng the 5-yea

te. Two of t

usquehanna 

se safety co

ues available

of the nucle

insights into

also receive

ECP norma

d by ECP du

outage times

ated to perso

s in the oper

ived by ECP

which has be

ducted at the

regarding th

the results w

s manager w

ns regarding

perator staffin

nd nature of

environment 

eas of conce

ties. Attentio

nd continued

ved by 

garding 

) 

number 

sis 

erns 

and 

ons of 

erning 

f the 

Most of 

 

13 

not indicate

ived by the N

, three in CY

ar review per

he discrimin

was comple

ncerns. The

e for raising 

ear safety cu

o the safety c

ed more con

ally receives 

uring the spr

s. ECP attrib

onal accoun

rations and t

P in CY 2012

een a trend 

e Susquehan

e operations

were still bei

was brought 

g operations 

ng issues re

f allegations 

problem wit

ern still exist 

on is focuse

 staffing con

0

10

20

30

2008

Subs

 2012 A

e a trend in a

NRC in CY 2

Y 2011, three

riod of 2008

nation conce

eted in July 2

e inspection 

safety conce

ulture survey

culture of the

ncerns in CY

more conce

ing 2012 Su

buted this inc

tability and b

training depa

2. There we

area in the p

nna Steam E

s organizatio

ng evaluate

on board in 

since the hi

emain a focu

received by

th the overal

and are bei

d in the ope

ncerns. 

2009 20

FIGURE 7 -

ALLEGATIO

tantiated

ANNUAL TR

any specific f

2012 repres

e in CY 2010

-2012, the a

rns raised in

2012 and fou

concluded t

erns. In add

y conducted 

e Susqueha

Y 2012 (abou

erns during o

usquehanna 

crease prim

behavioral o

artments. O

ere no ECP t

past. 

Electric Stati

on (a survey

d at the time

late 2012. 

ring of the n

s area for E

y the NRC fr

l population 

ng monitore

rations area

10 2011

WATTS BAR

ONS

Closed

RENDS REP

functional ar

ents an incr

0 and four in

agency has b

n CY 2012 

und an over

that site wor

dition, the PI

in March 20

nna 1 and 2

ut 30 more 

outage perio

Unit 1 refue

arily to comp

observation, 

Only two 

trends in the

on in 

y was conduc

e this report 

Susquehann

new operatio

CP. 

om onsite 

of workers a

ed by the NR

a as a result 

2012

R 1 

Received

PORT 

rea 

rease 

n

been 

rall 

rkers 

&R 

011 

2

ods, 

eling 

pany 

e

cted 

was 

na 

ons 

at 

RC 

of 
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

14 

the concerns received about the FFD program and chilling effect can be attributed to this event. 

The allegation receipt rate declined after the first quarter of CY 2012. Allegations were received 

primarily from licensee employees, both current and former. No allegations were received from 

anonymous sources. 

There have been nine discrimination concerns received by NRC related to Watts Bar Unit 1 

from CY 2008 through CY 2012. To date none have been substantiated. There were four 

received in CY 2012, an increase from the one received CY 2011. There were six allegation 

concerns received in CY 2012 asserting a chilled work environment. Four of the six were 

associated with the FFD issue mentioned earlier. The NRC did not substantiate a chilled work 

environment. 

The last biennial PI&R inspection at Watts Bar Unit 1 was completed in March 2011. The 

inspection found that licensee management emphasized to employees the importance of 

reporting concerns, that reporting avenues are readily accessible, and that the workforce was 

willing to raise nuclear safety concerns. 

The Watts Bar ECP continues to receive contacts at a consistent rate, but there was a decline in 

the receipt of nuclear safety concerns requiring full investigation. Since these types of concerns 

compare most directly with the types of concerns the NRC receives as allegations, the licensee 

conducted an analysis to compare recent ECP concern receipt rates to NRC allegation receipt 

rates. The analysis showed that NRC allegation receipt has been increasing while ECP 

concerns have been decreasing over the past 3 years. The licensee interpreted the results of 

the analysis as a lack of confidence in the ECP and took actions to address that finding. 

The licensee conducted a fleet-wide nuclear safety culture survey in the fourth quarter of 2011 

in response to a December 22, 2009, NRC Confirmatory Order. The survey results showed a 

substantial decline in employee perceptions from those reported in 2009 at Watts Bar, 

particularly in the SCWE area. The survey participation rate was only 61 percent, and was 

particularly low in parts of the operations and security organizations. The survey identified 

needed improvements in several areas, including SCWE and the corrective action program. 

SCWE weaknesses were identified in several departments. 

Tennessee Valley Authority (TVA) completed an Apparent Cause Analysis in October 2012 

regarding potential reasons behind the increase in the numbers of allegations received by the 

NRC. The licensee determined there were weaknesses in the three primary avenues for raising 

concerns (providing concerns to supervisors, the corrective action program, and the ECP), as 

well as weakness in communications regarding the resolution of concerns raised through those 

processes. Furthermore, the licensee concluded that they failed to recognize signs of the 

weakening SCWE from several sources, such as ECP pulsing data, safety culture survey 

results, and Nuclear Safety Review Board (NSRB) observations. Corrective actions have been 

initiated. 

In summary, while there was a significant increase in allegations received by the NRC from 

onsite sources at Watts Bar Unit 1 in 2012, most were received in the first quarter of the year 

and resulted from employee perceptions related to one onsite event. The license recognized 

the increase and did an extensive analysis to explain it. Based on that analysis and the recent 

nuclear safety culture survey results, the licensee appears to have developed a comprehensive 

corrective action plan. The NRC is maintaining its oversight of the SCWE at Watts Bar Unit 1 

through normal inspection activities, with a particular focus on licensee efforts to assure that the 

corrective actions being taken in response to the Apparent Cause Analysis, which include 
ALLEGA

response

the SCW

concerns

Sequoya

The num

CY 2012

receipt ra

steam ge

Most of t

employee

anonymo

There wa

discrimin

NRC (fou

one in CY

in CY 20

substant

been set

Pre-Inves

Resolutio

The Sequ

Program 

safety/qu

investiga

2011. W

safety cu

the fourth

survey re

Sequoya

improvem

compete

investiga

Furtherm

noted, ho

support a

populatio

that pers

TVA com

behind th

determin

concerns

commun

Furtherm

from sev

observat

ATION PROG

e to the nucl

WE and impro

s. 

ah Units 1 an

mber of allega

 (19) increas

ate increase

enerator rep

he allegation

es (current o

ous sources

as also an in

nation conce

ur in CY 201

Y 2010, two 

08). To date

iated, howev

tled using th

stigation Alte

on process. 

uoyah Empl

received ma

uality concer

ation in CY 2

With regard to

ulture at TVA

h quarter of 

esults showe

ah; however,

ments (5-10 

nce and trus

ations, and th

more, the rati

owever, that

an assumptio

on. The surv

sons are trea

mpleted an A

he increase 

ed there we

s to supervis

ications rega

more, the lice

eral sources

ions. Corre

GRAM 

ear safety cu

oving the lice

nd 2

ations receiv

sed significa

d in the four

lacement ou

ns received 

or former) an

.

ncreasing tre

rns received

2, zero in C

in CY 2009

e, none have

ver, a numbe

he NRC’s 

ernative Dis

 

oyee Conce

any more nu

rns requiring

2012 than in 

o the assess

A sites, the li

2011 in resp

ed a decline 

 ratings for S

percent) in t

stworthiness

he ECP’s eff

ings for the c

t the survey 

on that the r

vey identified

ated negative

Apparent Cau

in the numb

ere weaknes

sors, the corr

arding the re

ensee conclu

s, such as E

ctive actions

 

ulture survey

ensee’s awa

ved by the N

antly from the

rth quarter o

utage on bot

in the third a

nd 

end of 

d by the 

Y 2011, 

, and six 

e been 

er have 

pute 

erns 

uclear 

g full 

CY 

sment of 

censee cond

ponse to a D

in employee

SCWE and E

the workforc

s of the ECP

forts to prote

corrective ac

participation

respondents

d an area fo

ely by peers

use Analysis

ers of allega

ses in the th

rective actio

esolution of c

uded that the

CP pulsing d

s have been

 

15 

y, are comp

areness of th

NRC from on

e number re

f CY 2012, t

th units and 

and fourth q

ducted a flee

December 22

e perception

ECP improv

ce’s percepti

P staff, the fa

ect the ident

ction program

n rate was on

s were rando

r improveme

s when raisin

s in October

ations receiv

hree primary

on program, 

concerns ra

ey failed to r

data, safety 

 initiated. 

0

5

10

15

20

2008

Sub

 2012 A

leted and ar

he health of 

nsite sources

eceived in CY

the time peri

a significant

uarter were 

et-wide nucl

2, 2009 NRC

ns from those

ved. Specific

ion of the EC

air and thoro

ity of concer

m were adeq

nly 60 perce

om or repres

ent in SCWE

ng concerns.

2012 regard

ved by the N

y avenues fo

and the ECP

ised through

recognize sig

culture surv

2009 2

FIGURE 8 - S

ALLEGATIO

stantiated

ANNUAL TR

re effective a

the environm

s regarding S

Y 2011 (0). 

iod that corr

t influx of con

received fro

ear safety c

C Confirmato

e reported in

cally, there w

CP’s visibility

ugh nature o

rned individu

quate and im

ent at Sequo

sentative of t

E related to t

. 

ding potentia

RC. The lic

r raising con

P), as well a

h those proc

gns of the w

vey results, a

2010 2011

SEQUOYAH 

ONS

Closed

RENDS REP

at maintainin

ment for rais

Sequoyah in

The allegat

elates with a

ntractors on

om contract 

culture surve

ory Order. T

n 2009 at 

were notable

y, the 

of the ECP 

uals. 

mproving. It

yah, too low

the entire 

the perceptio

al reasons 

censee 

ncerns (prov

s weakness

cesses. 

weakening SC

and NSRB 

2012

1 & 2 

Received

PORT 

ng 

sing 

n

ion 

a

 site. 

ey in 

The 

e

t is 

w to 

on 

viding 

s in 

CWE 
ALLEGA

In summ

sources a

period th

influx of c

to unders

survey re

The NRC

activities

taken in 

culture s

licensee’

Turkey P

The NRC

Units 3 a

CY 2012

allegation

mostly re

issues. M

during th

than in a

allegation

anonymo

An analy

of the alle

shows no

allegation

CY 2012

environm

received 

None of t

allegation

has been

discrimin

are close

both CY 

The lates

willingne

various a

inspectio

The Turk

Twenty-tw

power up

CY 2012

attributed

(the work

uprate w

ATION PROG

ary, while th

at Sequoyah

at correlates

contractors o

stand and ad

esults, the lic

C is maintain

, with a part

response to 

urvey, are co

s awareness

Point Units 3 

C received th

and 4 in CY 2

 are similar 

ns received 

egarding rad

More allegat

e second qu

ny other qua

n concern w

ous source in

ysis of the nu

egations rec

o SCWE-rela

n concerns w

 asserting a

ment and one

related to s

the five chill

ns were sub

n a slightly d

nation conce

ed and none

2011 and C

st NRC PI&R

ss of site wo

avenues ava

on team were

key Point EC

wo concerns

prate outage

, but only on

d the concer

ker populatio

ork that beg

GRAM 

here was a s

h in 2012, m

s with a stea

on site. The

ddress it. Ba

censee appe

ning its overs

icular focus 

the Apparen

ompleted an

s of the hea

and 4

he same num

2012 (17) as

to those of C

were primar

iation protec

tions were re

uarter of CY 

arter. Only o

was received 

n CY 2012. 

umber and n

ceived in CY

ated trends. 

were receive

 chilled work

e concern w

afety culture

ing effect 

bstantiated. 

ecreasing tr

rns over the

 have been 

Y 2012. 

R inspection 

orkers to rais

ailable for rai

e not aware 

CP received 

s were asso

e contractor a

ne concern w

rn volume pr

on at Turkey

gan in 2011).

 

ignificant inc

most were rec

am generato

e license rec

ased on that

ears to have

sight of the S

on licensee 

nt Cause An

nd are effect

lth of the en

mber of alleg

s in CY 2011

CY 2011 wit

rily from curr

ction 

eceived 

2012 

one 

by an 

nature 

Y 2012 

 Five 

ed in 

k

as 

e. 

There 

rend in 

e past five ye

substantiate

at Turkey P

se safety co

ising safety c

of other ind

more conce

ciated with N

administered

was associa

rimarily to th

y Point contin

. The Turke

 

16 

crease in the

ceived in the

or replaceme

cognized the

t analysis an

e developed 

SCWE at Se

efforts to as

nalysis, whic

tive at maint

vironment fo

gations from

1. The attrib

h a concentr

rent licensee

ears. All of t

ed. Four dis

Point comple

ncerns and 

concerns. S

ividuals who

erns in CY 20

NRC-regulat

d its own EC

ted with NR

e substantia

nues to rema

ey Point ECP

0

5

10

15

20

2008

FIGU

ALL

Substa

 2012 A

e NRC recei

e fourth quar

ent outage at

 increase an

nd the recen

a comprehe

equoyah thro

ssure that th

ch include re

aining the S

or raising co

m onsite sour

butes of the a

ration in the 

e employees

the 14 receiv

scrimination c

eted in Augus

noted that w

Site personn

o were afraid

012 (about 5

ted activity. 

CP and rece

C-regulated

al number of

ain very high

P received fe

2009 2010

URE 9 - TUR

LEGATIONS

antiated C

ANNUAL TR

pt of allegat

rter of CY 20

t both units a

nd did an ext

nt nuclear sa

ensive correc

ough normal

he corrective

esponse to th

SCWE and im

ncerns. 

rces regardin

allegations r

health phys

s and contra

ved during th

concerns we

st 2012 foun

workers were

el interviewe

d to raise con

50 more) tha

Additionally

ived many c

 activity. Lic

f contractors

h due to the 

ewer anonym

0 2011 2

RKEY POINT 

Closed R

RENDS REP

tions from on

012, the time

and a signifi

tensive anal

afety culture 

ctive action p

l inspection 

 actions bein

he nuclear s

mproving the

ng Turkey P

received in 

sics area. Th

ctor employ

hat time peri

ere received

nd an overal

e aware of th

ed by the NR

ncerns. 

an in CY 201

y, the extend

concerns in 

censee ECP

 on site 

extended po

mous concer

2012

3 & 4 

Received

PORT 

nsite 

e

icant 

lysis 

plan. 

ng 

afety 

e

oint 

he 

ees, 

iod 

d in 

l 

he 

RC 

1. 

ded 

P staff 

ower 

rns in 
ALLEGA

CY 2012

which we

substant

1,600 em

behavior

In summ

continued

and natu

problem 

through n

Indian Po

The num

CY 2012

the allega

security a

Most of t

sources w

licensee 

security a

concerns

equipme

involved 

fitness-fo

and acce

related to

One alleg

CY 2012

environm

the secu

specific a

related to

CY 2011

are being

concerns

The mos

willingne

various a

inspectio

Indian Po

the exce

issues in

allegation

In summ

Indian Po

ATION PROG

 than in CY 

ere received

iated by the 

mployees, an

rs with regard

ary, given th

d through CY

re of allegat

at the site. 

normal inspe

oint Units 2 a

mber of allega

 increased s

ations receiv

area (13 of 1

he allegation

were receive

employees 

area. The s

s that did not

nt or technic

discriminatio

or-duty, fatig

ess authoriza

o security. 

gation conce

 asserting a

ment (the con

rity area) an

allegation co

o safety cultu

 (3). Of the 

g evaluated 

s received in

st recent PI&

ss of site wo

avenues ava

on team were

oint ECP tre

ption of the s

 CY 2012 th

ns that conti

ary, the num

oint 2 and 3 

GRAM 

2011, but re

 from contra

ECP. The r

nd engagem

d to treating

he substantia

Y 2012 for th

tions receive

The NRC is 

ection activit

and 3

ations receiv

slightly from 

ved in CY 20

17 allegation

ns from onsi

ed from curr

also focused

ecurity-relat

t involve 

cal matters 

on, 

ue and over

ation matters

ern was rece

 chilled work

ncern was n

d there were

oncerns rece

ure. More d

five discrim

by the NRC 

n the past 4 y

&R inspection

orkers to rais

ailable for rai

e not aware 

nds in conce

security area

hat it has in t

inue to be re

mber and nat

does not ind

 

eceived more

actor employ

results of biw

ent surveys 

 employees 

al increase i

he Turkey P

ed regarding

maintaining

ties and inte

ved by NRC 

the number

012 are simi

ns). 

ite 

rent 

d in the 

ted 

rtime, 

s

eived in 

k

ot in 

e no 

eived 

discrimination

ination conc

(all related 

years have b

n at Indian P

se safety co

ising safety c

of other ind

erns receive

a. Specifica

the past, in c

eceived by th

ture of allega

dicate a wor

 

17 

e SCWE-rel

yees. None 

weekly outre

in 2012 indi

with respec

n the site po

Point extende

g the site in C

g its oversigh

ractions with

from onsite 

r received in 

lar to those 

n concerns w

cerns receive

to the secur

been substa

Point comple

ncerns, and 

concerns. S

ividuals who

ed in CY 201

ally, ECP did

contrast to th

he NRC. 

ations receiv

rk environme

0

5

10

15

20

2008

FIGU

ALL

Substa

 2012 A

ated concer

of the SCW

each session

icated impro

ct. 

opulation tha

ed power up

CY 2012 are

ht of the SCW

h site manag

sources reg

CY 2011 (1

of CY 2011 

were receive

ed in CY 201

rity area). N

antiated. 

eted in Augu

noted that w

Site personn

o were afraid

12 were sim

d not receive

he large volu

ved by the N

ent issue wit

2009 201

URE 10 - IND

EGATIONS

antiated

ANNUAL TR

rns in CY 20

E-related co

ns, involving

ovement in m

at began in la

prate outage

e not indicati

WE at Turke

gement. 

garding India

7 vs. 15). T

with primary

ed in CY 201

12, four rem

one of the 1

st 2011 foun

workers wer

el interviewe

d to raise con

ilar to previo

e the volume

ume of secu

NRC from on

h the overal

10 2011

DIAN POINT 2

Closed

RENDS REP

12 (14), 10 o

oncerns were

 approximat

management

ate CY 2010

, the numbe

ve of a SCW

ey Point 3 an

an Point in 

The attributes

y focus in th

12 (5) than i

ain open an

0 discrimina

nd an overal

e aware of t

ed by the PI

ncerns. 

ous years, w

e of security 

rity-related 

nsite sources

l population 

2012

2 & 3 

Received

PORT 

of 

e

tely 

t

0 and 

er 

WE 

nd 4 

s of 

e 

n 

d 

ation 

l 

he 

&R 

with 

s at 

of 
ALLEGA

workers a

in CY 20

by the fa

ECP was

NRC rem

normal in

of allegat

SCWE. 

Allegatio

The NRC

this repo

associate

a license

on allega

publicly o

received 

into the S

materials

Allegatio

Neither t

similar to

trends of

Shaw Mo

The NRC

& Iron’s (

as, Shaw

received 

SCWE a

period, th

of 54 ven

from all s

approxim

vendor-re

received 

period co

facility. T

related a

involved 

chilling e

alleging r

concerns

NRC not

2010-201

substant

These al

ATION PROG

at Indian Po

12 suggests

ct that in CY

s notably dim

mains high. T

nspection ac

tions related

on Trends f

C Web site p

rt). Because

ed with the o

ee or contrac

ations about 

or included i

a sufficient 

SCWE. The

s licensees. 

on Trends f

his report no

o those outlin

f one vendor

odular Soluti

C received a

(CB&I) Lake

w Modular So

19 allegatio

t SMS. Ove

he NRC rece

ndor-related 

sources. Th

mately 35 pe

elated allega

by the NRC

oncerned the

The 19 SMS

allegation con

10 concerns

effect and nin

retaliation af

s were raised

es an increa

12. Of the 1

iated by the 

legations we

GRAM 

oint. Howeve

s that focuse

Y 2012, the v

minished, wh

The NRC is 

ctivities, with

d to the secu

for Selected

posts allegat

e of the sma

overwhelmin

ctor to identif

materials lic

n this report

number of a

erefore, this r

 

for Selected

or the NRC W

ned above re

r warrant dis

ions

 significant n

e Charles, Lo

olutions (SM

ons regarding

er the same 

eived a total 

allegations 

erefore, 

rcent of all 

ations 

C during this 

e SMS 

S SCWEncerns 

s alleging a 

ne concerns 

fter safety 

d. The 

asing trend i

9 chilling eff

NRC and fo

ere received

 

er, the volum

ed attention i

volume of se

hile the volum

maintaining

 a particular

urity area ove

d Materials L

ion statistics

all number of

ng majority o

fy an alleger

censees othe

t. None of th

allegations to

report does 

d Vendors 

Web site pro

egarding ma

scussion in th

number of a

ouisiana faci

MS)). From C

g SMS, 13 o

n the numbe

fect and disc

our were still

d from multip

 

18 

0

2

4

6

2008

FIGUR

ALLE

Substantia

me of securit

is needed in

ecurity conce

me of securi

g its oversigh

r focus on lic

er the past f

Licensees

s for certain 

f allegations

of other smal

r is increase

er than fuel 

he materials 

o discern a t

not include m

ovides statist

aterials licen

his report. 

llegations fro

lity (formerly

CY 2010 thr

of which rais

er of concern

crimination/r

 open at the

ple concerne

 2012 A

2009 2010

RE 11 - SHAW

GATIONS

ted Clos

ty-related all

n the security

erns raised i

ity-related al

ht of the SCW

censee effort

few years ha

fuel cycle fa

s and the sm

ller materials

d. For this r

cycle facilitie

licensees o

trend or patte

more in-dep

tics by contr

sees. None

om onsite so

y known as, 

ough CY 20

sed 19 separ

ns related to

retaliation co

e time this re

ed individuals

ANNUAL TR

2011 2012

W MODULAR

sed Rec

egations/co

y area. This

nternally via

llegations su

WE at Indian

ts to assure 

as not advers

acilities (see 

maller work fo

s licensees, 

reason, table

es have not 

or fuel cycle f

ern or to pro

pth reviews o

ractor or ven

etheless, the

ources at Ch

and referred

012, into earl

rate concern

o SCWE at S

oncerns, five

eport was be

s. 

RENDS REP

2

R SOLUTION

ceived

ncerns rece

s is emphasiz

a the Indian 

ubmitted to t

n Point throu

that the volu

sely affected

the append

orce sizes 

the potentia

es of statistic

been provid

facilities 

ovide insight

of specific 

ndor for reas

e allegation 

hicago Bridg

d to in this re

ly 2013, the 

ns related to 

SMS from 

e were 

eing written. 

PORT 

NS

ived 

zed 

Point 

he 

ugh 

ume 

d the 

ix to 

al for 

cs 

ded 

ts 

sons 

e 

eport 

NRC 

the 
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

19 

The vendor conducted a SCWE assessment for SMS in February 2012. The assessment 

identified that a chilled work environment exists at SMS. The results indicated that a number of 

respondents are not confident they can raise a quality concern without fear of retaliation, know 

of someone who has experienced a negative reaction from management after raising a quality 

concern, and do not believe the SMS discipline policy is appropriate or fair. In all of these 

areas, the assessment results demonstrate higher negative response rates than industry norms. 

The NRC conducted three inspections and two allegation follow-up SCWE assessments at the 

SMS facility and, on the basis of its observations, reached the same conclusion as the vendor’s 

assessment. The NRC identified (1) a perceived fear of retaliation for raising safety concerns, 

(2) that SMS employees mistrust management, (3) that craft employees lack adequate 

knowledge on proper use of the corrective action program, and (4) that the corrective action 

program is ineffective at resolving conditions adverse to quality. Furthermore, the NRC 

observed that employees most knowledgeable about what constitutes a nuclear safety issue 

were the most hesitant to raise such concerns. These NRC observations resulted in the 

substantiation of five allegations of a chilled work environment. Furthermore, the NRC observed 

that in the year that followed the vendor’s assessment, only minimal actions were taken by the 

vendor to remedy the identified chilled work environment at SMS and that they had not been 

effective in remedying the problems. 

Lastly, the NRC identified issues in the effectiveness of the corrective action program. 

Specifically, the NRC found that SMS site employees do not understand that a corrective action 

program is a tool to be used in correcting conditions adverse to quality. This lack of 

understanding is most pronounced among craft employees, who rarely used the corrective 

action program to document nonconforming items. 

In summary, although the NRC did not identify unreported safety issues in its assessments, 

NRC staff determined some employees are reluctant to raise safety issues to their 

management. As this report was being written, the NRC was discussing the need for 

heightened regulatory oversight to ensure the vendor takes timely and effective actions to 

address existing SCWE issues and improve the environment for raising concerns at the facility. 

On April 18, 2013, the staff issued a Chilling Effect Letter to this vendor citing the agency’s 

concerns about the SCWE at the Lake Charles, LA site, and requesting information regarding 

the vendor’s plans to address those concerns (ADAMS Accession No. ML13092A077). 

Agreement State Trends

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

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

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

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

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

protect public health and safety and are compatible with the NRC’s program. Figure 12 depicts 

the 37 Agreement States. 
ALLEGA

The NRC

to ensure

compatib

The NRC

statutory 

available

Program

In CY 20

The revie

concerns

cumulativ

reviewed

from con

conclude

concerns

States do

notifying 

identities

adequate

Overall, w

Agreeme

priority in

the review

Georgia, 

staff is cl

ATION PROG

C has statuto

e that they m

ble with the a

C uses the In

responsibili

e on the NRC

s Web site a

12, the NRC

ew teams ev

s from extern

vely received

d to the Agre

cerned indiv

ed that the S

s raised. In 

ocumented t

concerned i

s were know

ely protected

with one exc

ent States co

n protecting 

w team to be

is implemen

osely monito

GRAM 

FIG

ory responsi

maintain prog

agency’s pro

ntegrated Ma

ity. More inf

C’s Office of 

at http://nrc-s

C conducted

valuated the 

nal sources 

d by all of th

eement State

viduals. In a

States consis

all Agreeme

the results o

individuals o

n. Review t

d the identity

ception, the 

ontinue to ra

public health

e unsatisfac

nting recomm

oring those a

 

GURE 12 - A

bility to revie

grams adequ

ogram. This

aterials Perf

formation on

Federal and

stp.ornl.gov/

 routine IMP

effectivenes

by reviewing

he programs

e Programs;

all Agreemen

stently took p

ent State Pro

of their inves

of the outcom

eams determ

y of any conc

results of the

ank response

h and safety

ctory in the p

mendations 

actions. 

Agreement 

NRC States

 

20 

AGREEMEN

ew periodica

uate to prote

s authority is 

formance Ev

n the NRC’s 

d State Mate

/. 

PEP reviews

ss of the Agr

g the casewo

 reviewed. T

 the States r

nt State Prog

prompt and a

ograms, exce

tigations and

mes of the in

mined that th

cerned indiv

e CY 2012 I

e to concern

y. The Agree

program’s rev

to strengthe

States (37)

s (13)

 2012 A

NT STATES 

ally the actio

ect public he

granted und

valuation Pro

Agreement 

erials and En

 of eight Agr

reement Sta

ork and doc

The NRC re

received the

grams, exce

appropriate 

ept one, the 

d closeout a

nvestigations

he States re

vidual who re

MPEP revie

ns from exter

ement State

view and res

en its allegat

ANNUAL TR

ns of the Ag

ealth and saf

der Section 

ogram (IMPE

State Progra

nvironmenta

reement Sta

ate Programs

umentation f

eferred 18 of

e other conce

ept one, the r

action in res

review team

actions, whic

s when the in

viewed in CY

equested an

ews demons

rnal sources

 Program th

sponse to al

tion program

RENDS REP

greement Sta

fety and are 

274j of the A

EP) to satisfy

am or IMPE

al Manageme

ate Programs

s’ responses

for 42 cases

f the 42 case

erns directly

review team

sponse to 

ms noted tha

ch included 

ndividuals’ 

Y 2012 

onymity. 

trate that the

s as a high 

at was found

llegations, 

m and the NR

PORT 

ates 

Act. 

y its 

P is 

ent 

s. 

s to 

s

es 

y

s 

at the 

e

d by 

RC 
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

21 

CONCLUSIONS

More allegations were received in CY 2012 than in CY 2011. The 5 percent increase reflects 

significant activity at a limited number of sites. The largest percentage of concerns received 

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

CY 2011. Notable increases were also seen in chilling effect, corrective action, maintenance, 

and engineering concerns. While the number of security-related concerns also remained at a 

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

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

trends for reactors and materials facilities do not suggest a concern about the environment for 

raising concerns; however, the NRC continues to closely monitor one vendor facility to ensure 

timely and effective actions are taken to address existing SCWE issues. One Agreement State 

Program, Georgia’s, was found unsatisfactory and the NRC is monitoring the State’s actions to 

strengthen its allegation program. 

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

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

believes that voluntary dispute resolution by the parties using the communication opportunities 

afforded in Early ADR can stem the inherent damage such disputes have on the SCWE more 

quickly than an investigation. 
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

A-1

APPENDIX 

ALLEGATION STATISTICS 

OPERATING REACTORS AND FUEL CYCLE FACILITIES

OPERATING REACTOR ALLEGATIONS RECEIVED FROM ONSITE SOURCES 

Site 2008 2009 2010 2011 2012 

ARKANSAS 1 & 2 6 3 4 3 6

BEAVER VALLEY 1 & 2 3 1 2 1 1

BRAIDWOOD 1 & 2 3 3 4 2 2

BROWNS FERRY 1, 2 & 3 18 8 12 11 16

BRUNSWICK 1 & 2 2 5 1 3 6

BYRON 1 & 2 8 9 6 3 3

CALLAWAY 2 2 3 1 5

CALVERT CLIFFS 1 & 2 3 1 1

CATAWBA 1 & 2 3 2 2 3 3

CLINTON 1 4 4 1 1

COLUMBIA PLANT 1 9 4 5 1

COMANCHE PEAK 1 & 2 5 1 2 3 2

COOK 1 & 2 5 5 3 5 

COOPER 3 2 5 5 3

CRYSTAL RIVER 2 4 4 1 1

DAVIS-BESSE 1 2 4 

DIABLO CANYON 1 & 2 13 15 12 9 5

DRESDEN 2 & 3 8 5 1 2 

DUANE ARNOLD 2 1 1 1 2

FARLEY 1 & 2 5 6 7 12 9

FERMI 3 3 3 3 1

FITZPATRICK 2 3 2 2 2

FORT CALHOUN 1 4 5 4 3

GINNA 4 2 4 10 4

GRAND GULF 4 2 5 3 10

HARRIS 1 2 5 3 6

HATCH 1 & 2 7 5 8 4 5

INDIAN POINT 2 & 3 3 11 6 15 17

KEWAUNEE 3 1 1

LASALLE 1 & 2 1 1 2 

LIMERICK 1 & 2 3 14 2 3 5

MCGUIRE 1 & 2 3 3 6 5 1

MILLSTONE 2 & 3 8 5 4 11 9

MONTICELLO 2 2 3 2

NINE MILE POINT 1 & 2 1 1 5 2

NORTH ANNA 1 & 2 1 1 2 1 1

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

OYSTER CREEK 6 14 4 3

PALISADES 6 8 3 5 5

PALO VERDE 1, 2, & 3 17 15 16 8 7
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

A-2

Site 2008 2009 2010 2011 2012 

PEACH BOTTOM 2 & 3 3 8 4 3 1

PERRY 6 9 2 5 10

PILGRIM 8 1 5 5 2

POINT BEACH 1 & 2 5 4 8 6 4

PRAIRIE ISLAND 1 & 2 5 14 8 7 9

QUAD CITIES 1 & 2 4 2 1 1

RIVER BEND 8 5 7 

ROBINSON 1 4 6 4

SALEM/HOPE CREEK 11 7 6 4 5

SAN ONOFRE 2 & 3 18 33 57 23 28

SEABROOK 10 2 1 7 5

SEQUOYAH 1 & 2 19 6 6 19

SOUTH TEXAS 1 & 2 8 12 5 5 8

ST LUCIE 1 & 2 6 15 12 16 7

SUMMER 2 3 1 4 1

SURRY 1 & 2 2 2 6 4 1

SUSQUEHANNA 1 & 2 32 15 12 22 21

THREE MILE ISLAND 2 9 1 3 

TURKEY POINT 3 & 4 19 14 15 17 17

VERMONT YANKEE 1 2 3 2 

VOGTLE 1 & 2 1 2 4 12 5

WATERFORD 4 3 4 2 4

WATTS BAR 1 9 3 2 5 21

WOLF CREEK 7 6 2 4 5
ALLEGATION PROGRAM 2012 ANNUAL TRENDS REPORT 

A-3

FUEL CYCLE FACILITY ALLEGATIONS RECEIVED FROM ONSITE SOURCES 

Site 2008 2009 2010 2011 2012 

AMERICAN CENTRIFUGE PLANT 2 1

BWX TECHNOLOGIES, INC. 1 2 1 

GLOBAL NUCLEAR FUEL 1 1 6 6 5

HONEYWELL 1 4 7 16 3

LOUISIANA ENERGY SERVICES 1 11 29 6 12

NUCLEAR FUEL SERVICES, INC. 3 3 5 10 4

PADUCAH 5 3 4 5 6

PORTSMOUTH 2 1 

SHAW AREVA MOX SERVICES 2 1 1 4

WESTINGHOUSE 2 4 2 1

YUCCA MOUNTAIN 1 5 2