80 FR 11693 - Scope Expansion of the Post-Investigation Alternative Dispute Resolution Program

NUCLEAR REGULATORY COMMISSION

Federal Register Volume 80, Issue 42 (March 4, 2015)

Page Range		11693-11695
FR Document		2015-04490
The U.S. Nuclear Regulatory Commission (NRC) is issuing a revision to its Enforcement Policy (Enforcement Policy or Policy) to incorporate Commission direction to add escalated non-willful (traditional) enforcement cases with the potential for civil penalties within the scope of the Commission's Alternative Dispute Resolution Program and to make other conforming edits.
Federal Register, Volume 80 Issue 42 (Wednesday, March 4, 2015)
[Federal Register Volume 80, Number 42 (Wednesday, March 4, 2015)]
[Notices]
[Pages 11693-11695]
From the Federal Register Online  [www.thefederalregister.org]
[FR Doc No: 2015-04490]


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NUCLEAR REGULATORY COMMISSION

[NRC-2013-0046]


Scope Expansion of the Post-Investigation Alternative Dispute 
Resolution Program

AGENCY: Nuclear Regulatory Commission.

ACTION: Policy revision; issuance.

-----------------------------------------------------------------------

SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is issuing a 
revision to its Enforcement Policy (Enforcement Policy or Policy) to 
incorporate Commission direction to add escalated non-willful 
(traditional) enforcement cases with the potential for civil penalties 
within the scope of the Commission's Alternative Dispute Resolution 
Program and to make other conforming edits.

DATES: This revision to the Enforcement Policy is effective March 4, 
2015.

ADDRESSES: Please refer to Docket ID NRC-2013-0046 when contacting the 
NRC about the availability of information for this action. You may 
obtain publicly-available information related to this action by any of 
the following methods:
     Federal Rulemaking Web site: Go to http://www.regulations.gov and search for Docket ID NRC-2013-0046. Address 
questions about NRC dockets to Carol Gallagher; telephone: 301-415-
3463; email: [email protected]. For technical questions, contact 
the individuals listed in the FOR FURTHER INFORMATION CONTACT section 
of this document.
     NRC's Agencywide Documents Access and Management System 
(ADAMS): You may obtain publicly-available documents online in the 
ADAMS Public Documents collection at http://www.nrc.gov/reading-rm/adams.html. To begin the search, select ``ADAMS Public Documents'' and 
then select ``Begin Web-based ADAMS Search.'' For problems with ADAMS, 
please contact the NRC's Public Document Room (PDR) reference staff at 
1-800-397-4209, 301-415-4737, or by email to [email protected]. The 
ADAMS accession number for each document referenced (if it is available 
in ADAMS) is provided the first time that it is mentioned in the 
SUPPLEMENTARY INFORMATION section.
     NRC's PDR: You may examine and purchase copies of public 
documents at the NRC's PDR, Room O1-F21, One White Flint North, 11555 
Rockville Pike, Rockville, Maryland 20852.

FOR FURTHER INFORMATION CONTACT: Daniel Lenehan, telephone: 301-415-
3501, email: [email protected], or Shahram Ghasemian, telephone: 
301-415-3591, email: [email protected]; both of the Office of 
Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-
0001.

SUPPLEMENTARY INFORMATION:

Background

    The Administrative Dispute Resolution Act of 1996 authorizes and 
encourages the use of Alternative Dispute Resolution (ADR) procedures 
by Federal agencies. The term ``ADR'' refers to a number of voluntary 
processes, such as mediation and facilitated dialogues that can be used 
to assist parties in resolving disputes and potential conflicts. These 
techniques involve the use of a neutral third party, either from within 
the agency or from outside the agency, and are voluntary processes in 
terms of the decision to participate and the content of the final 
agreement. The NRC's experience with ADR has demonstrated that the use 
of these techniques can result in more efficient resolution of issues, 
more effective outcomes, and improved relationships between the agency 
and other parties. The NRC established the ADR Program in its Office of 
Enforcement in 2004.
    Since the implementation of the ADR Program, the NRC has reached 
settlement agreements with licensees (or contractors) and individuals, 
and has issued subsequent ADR confirmatory orders in more than 90 
enforcement cases. The parties to ADR in the NRC's enforcement program 
are the NRC staff and, in most cases, a licensee. The proceedings are 
conducted using the facilitation skills of a trained independent 
mediator. Mediation allows the NRC staff and the licensee to 
communicate openly and directly and enables the parties to reach 
effective and workable agreements that meet the NRC's regulatory 
interests. Historically,

[[Page 11694]]

the ADR Program has resulted in broader and more comprehensive 
corrective actions than would be expected using traditional enforcement 
means.
    On December 16, 2010, then NRC Chairman, Gregory Jaczko, issued a 
memorandum, ``ADR Implementation and Assessment'' (ADAMS Accession No. 
ML12030A228) tasking the NRC staff to conduct a comprehensive review of 
the ADR Program, including determining if it should be expanded. At the 
time the ADR Program was limited to cases involving discrimination and 
other wrong doing. On September 6, 2011, the NRC issued a notice in the 
Federal Register that solicited nominations of individuals to 
participate on a panel to discuss ADR Program implementation and 
whether changes could be made to make it more effective, transparent, 
and efficient (76 FR 55136). On October 17, 2011, the NRC issued 
another Federal Register notice that announced its intention to hold a 
public meeting to solicit feedback from its stakeholders on the ADR 
Program (76 FR 64124). During the public meeting, which was held on 
November 8, 2011, external NRC stakeholders expressed support for the 
expansion of the ADR Program to the extent possible.
    In Commission Paper SECY-12-0161, ``Status Update, Tasks Related to 
Alternative Dispute Resolution in the Allegation and Enforcement 
Programs,'' dated November 28, 2012 (ADAMS Accession No. ML12321A145), 
the NRC staff notified the Commission of its intent to pilot the 
expansion of the ADR Program to include escalated non-willful 
(traditional) enforcement cases with proposed civil penalties for a 1-
year period. The expansion of the program did not include violations 
associated with findings assessed through the Reactor Oversight 
Process.
    During the pilot period, the NRC staff made ADR available for seven 
escalated non-willful (traditional) enforcement cases with proposed 
civil penalties however, none of the licensees chose ADR. The licensees 
included a waste disposal facility, two radiographers, a gauge user, 
two hospitals, and one non-operating (decommissioned) reactor. However, 
shortly after the 1-year period, a power reactor licensee chose to 
engage in ADR for an escalated non-willful (traditional) enforcement 
case with the potential for a civil penalty. The subsequent mediation 
resulted in a settlement, specified in the Confirmatory Order, under 
which the licensee agreed to fleet-wide actions as opposed to plant-
specific actions that would have typically been expected from using the 
traditional enforcement process.
    In Commission Paper SECY-14-0077, ``Status Update and Proposed 
Policy Revision: Tasks Related to Alternative Dispute Resolution in the 
Enforcement Program,'' dated July 30, 2014 (ADAMS Accession No. 
ML14143A363), the NRC staff recommended that the Commission approve 
expanding the scope of the ADR Program to include non-willful 
(traditional) enforcement cases with the potential for civil penalties 
(not including violations associated with findings assessed through the 
Reactor Oversight Process).
    In the Staff Requirements Memorandum to SECY-14-007, the Commission 
approved the expansion of the ADR Program. Accordingly, the NRC is 
revising Section 2.4.3, ``Alternate Dispute Resolution,'' of the 
Enforcement Policy to add escalated non-willful (traditional) 
enforcement cases with the potential for civil penalties within the 
scope of the program and to make other conforming edits.

Revisions to Enforcement Policy

    The text of revised section 2.4.3, in its entirety, follows. A 
marked copy of the Enforcement Policy is available in ADAMS under 
Accession No. ML15028A422.

2.4.3 Alternative Dispute Resolution

    The Administrative Dispute Resolution Act of 1996 (ADRA) authorizes 
and encourages the use of Alternative Dispute Resolution (ADR) 
procedures by Federal agencies. ADR refers to a variety of processes 
that emphasize creative, cooperative approaches to handling conflicts 
in lieu of adversarial procedures. Mediation is the form of ADR 
typically used by the U.S. Nuclear Regulatory Commission (NRC). The use 
of ADR in the NRC's enforcement program is available for cases 
involving discrimination and other wrongdoing as well as escalated 
nonwillful (traditional) enforcement cases with the potential for civil 
penalties (not including violations associated with findings assessed 
through the Reactor Oversight Process).
    ADR may also be used for discrimination violations based solely on 
a finding by DOL; however, the NRC will not negotiate the DOL finding. 
Individuals within the Commission's jurisdiction may also be offered 
ADR. ADR complements, and works in conjunction with, the traditional 
NRC enforcement process. ADR may be offered (1) before a predecisional 
enforcement conference (PEC), (2) after the initial enforcement action 
is taken (i.e., an NOV or proposed imposition of a civil penalty), or 
(3) with the imposition of a civil penalty and prior to a hearing 
request. Use of the ADR program is voluntary for all parties, including 
the NRC; any participant may end the process at any time. Mediation 
activities are kept confidential in accordance with 5 U.S.C. 574; 
however, the terms of the settlement agreement are normally formalized 
in a Confirmatory Order, which is published in the Federal Register. 
Normally, there is also a press release providing information about the 
settlement agreement.
    In some circumstances, it may not be appropriate for the NRC to 
engage in ADR (e.g., the U.S. Department of Justice has substantial 
involvement in the case, cases in which the subject matter is such that 
a Confirmatory Order detailing the terms of a settlement agreement 
cannot be made public, or other particularly egregious cases in which 
the public interest is not served by engaging in ADR). The approval of 
the Director, OE, is required in those cases where the staff proposes 
not to offer ADR.
    Additional information concerning the NRC's ADR program is 
available in the NRC Enforcement Manual and on the NRC Web site.
    In addition, an individual and his or her employer (or former 
employer) can use ADR to resolve discrimination complaints (under 
Section 211 of the ERA) before the initiation of investigative 
activities by OI (i.e., pre-investigation ADR, commonly referred to as 
``early ADR'') (see NRC Management Directive 8.8, ``Management of 
Allegations'') or a licensee-sponsored ADR program that is similar in 
nature to the NRC's early ADR program. If the parties reach a 
settlement agreement using early ADR or licensee-sponsored ADR, the NRC 
subsequently reviews the agreement to ensure that it does not include 
any provisions in violation of the NRC's ``Employee Protection'' 
regulations. If no such restrictive provisions exist, the NRC will not 
investigate the discrimination complaint or take enforcement action.

Congressional Review Act

    This policy revision is a rule as defined in the Congressional 
Review Act (5 U.S.C. 801-808). However, the Office of Management and 
Budget has not found it to be a major rule as defined in the 
Congressional Review Act.

    Dated at Rockville, Maryland, this 26th day of February, 2015.


[[Page 11695]]


    For the Nuclear Regulatory Commission.
Annette L. Vietti-Cook,
Secretary of the Commission.
[FR Doc. 2015-04490 Filed 3-3-15; 8:45 am]
BILLING CODE 7590-01-P
11694 Federal Register / Vol. 80, No. 42 / Wednesday, March 4, 2015 / Notices

the ADR Program has resulted in from using the traditional enforcement a civil penalty), or (3) with the
broader and more comprehensive process. imposition of a civil penalty and prior
corrective actions than would be In Commission Paper SECY–14–0077, to a hearing request. Use of the ADR
expected using traditional enforcement ‘‘Status Update and Proposed Policy program is voluntary for all parties,
means. Revision: Tasks Related to Alternative including the NRC; any participant may
On December 16, 2010, then NRC Dispute Resolution in the Enforcement end the process at any time. Mediation
Chairman, Gregory Jaczko, issued a Program,’’ dated July 30, 2014 (ADAMS activities are kept confidential in
memorandum, ‘‘ADR Implementation Accession No. ML14143A363), the NRC accordance with 5 U.S.C. 574; however,
and Assessment’’ (ADAMS Accession staff recommended that the Commission the terms of the settlement agreement
No. ML12030A228) tasking the NRC approve expanding the scope of the are normally formalized in a
staff to conduct a comprehensive review ADR Program to include non-willful Confirmatory Order, which is published
of the ADR Program, including (traditional) enforcement cases with the in the Federal Register. Normally, there
determining if it should be expanded. potential for civil penalties (not is also a press release providing
At the time the ADR Program was including violations associated with information about the settlement
limited to cases involving findings assessed through the Reactor agreement.
discrimination and other wrong doing. Oversight Process).
In the Staff Requirements In some circumstances, it may not be
On September 6, 2011, the NRC issued
Memorandum to SECY–14–007, the appropriate for the NRC to engage in
a notice in the Federal Register that
Commission approved the expansion of ADR (e.g., the U.S. Department of
solicited nominations of individuals to
the ADR Program. Accordingly, the NRC Justice has substantial involvement in
participate on a panel to discuss ADR
is revising Section 2.4.3, ‘‘Alternate the case, cases in which the subject
Program implementation and whether
changes could be made to make it more Dispute Resolution,’’ of the Enforcement matter is such that a Confirmatory Order
effective, transparent, and efficient (76 Policy to add escalated non-willful detailing the terms of a settlement
FR 55136). On October 17, 2011, the (traditional) enforcement cases with the agreement cannot be made public, or
NRC issued another Federal Register potential for civil penalties within the other particularly egregious cases in
notice that announced its intention to scope of the program and to make other which the public interest is not served
hold a public meeting to solicit feedback conforming edits. by engaging in ADR). The approval of
from its stakeholders on the ADR the Director, OE, is required in those
Revisions to Enforcement Policy cases where the staff proposes not to
Program (76 FR 64124). During the
public meeting, which was held on The text of revised section 2.4.3, in its offer ADR.
November 8, 2011, external NRC entirety, follows. A marked copy of the Additional information concerning
stakeholders expressed support for the Enforcement Policy is available in the NRC’s ADR program is available in
expansion of the ADR Program to the ADAMS under Accession No. the NRC Enforcement Manual and on
extent possible. ML15028A422. the NRC Web site.
In Commission Paper SECY–12–0161, 2.4.3 Alternative Dispute Resolution In addition, an individual and his or
‘‘Status Update, Tasks Related to her employer (or former employer) can
Alternative Dispute Resolution in the The Administrative Dispute
use ADR to resolve discrimination
Allegation and Enforcement Programs,’’ Resolution Act of 1996 (ADRA)
complaints (under Section 211 of the
dated November 28, 2012 (ADAMS authorizes and encourages the use of
ERA) before the initiation of
Accession No. ML12321A145), the NRC Alternative Dispute Resolution (ADR)
investigative activities by OI (i.e., pre-
staff notified the Commission of its procedures by Federal agencies. ADR
investigation ADR, commonly referred
intent to pilot the expansion of the ADR refers to a variety of processes that
to as ‘‘early ADR’’) (see NRC
Program to include escalated non- emphasize creative, cooperative
Management Directive 8.8,
willful (traditional) enforcement cases approaches to handling conflicts in lieu
‘‘Management of Allegations’’) or a
with proposed civil penalties for a 1- of adversarial procedures. Mediation is
licensee-sponsored ADR program that is
year period. The expansion of the the form of ADR typically used by the
similar in nature to the NRC’s early ADR
program did not include violations U.S. Nuclear Regulatory Commission
program. If the parties reach a
associated with findings assessed (NRC). The use of ADR in the NRC’s
settlement agreement using early ADR
through the Reactor Oversight Process. enforcement program is available for
or licensee-sponsored ADR, the NRC
During the pilot period, the NRC staff cases involving discrimination and
subsequently reviews the agreement to
made ADR available for seven escalated other wrongdoing as well as escalated
ensure that it does not include any
non-willful (traditional) enforcement nonwillful (traditional) enforcement
provisions in violation of the NRC’s
cases with proposed civil penalties cases with the potential for civil
however, none of the licensees chose ‘‘Employee Protection’’ regulations. If
penalties (not including violations
ADR. The licensees included a waste no such restrictive provisions exist, the
associated with findings assessed
disposal facility, two radiographers, a NRC will not investigate the
through the Reactor Oversight Process).
gauge user, two hospitals, and one non- ADR may also be used for discrimination complaint or take
operating (decommissioned) reactor. discrimination violations based solely enforcement action.
However, shortly after the 1-year period, on a finding by DOL; however, the NRC Congressional Review Act
a power reactor licensee chose to engage will not negotiate the DOL finding.
in ADR for an escalated non-willful Individuals within the Commission’s This policy revision is a rule as
defined in the Congressional Review
mstockstill on DSK4VPTVN1PROD with NOTICES

(traditional) enforcement case with the jurisdiction may also be offered ADR.
potential for a civil penalty. The ADR complements, and works in Act (5 U.S.C. 801–808). However, the
subsequent mediation resulted in a conjunction with, the traditional NRC Office of Management and Budget has
settlement, specified in the enforcement process. ADR may be not found it to be a major rule as
Confirmatory Order, under which the offered (1) before a predecisional defined in the Congressional Review
licensee agreed to fleet-wide actions as enforcement conference (PEC), (2) after Act.
opposed to plant-specific actions that the initial enforcement action is taken Dated at Rockville, Maryland, this 26th day
would have typically been expected (i.e., an NOV or proposed imposition of of February, 2015.

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Federal Register / Vol. 80, No. 42 / Wednesday, March 4, 2015 / Notices 11695

For the Nuclear Regulatory Commission. SECURITIES AND EXCHANGE September 30, 2014, the Commission
Annette L. Vietti-Cook, COMMISSION received a letter from FINRA responding
Secretary of the Commission. to the comment letters.5 On October 1,
[Release No. 34–74383; File No. SR–FINRA–
[FR Doc. 2015–04490 Filed 3–3–15; 8:45 am] 2014–028]
2014, the Commission issued an order
to institute proceedings pursuant to
BILLING CODE 7590–01–P
Self-Regulatory Organizations; section 19(b)(2)(B) of the Act 6 to
Financial Industry Regulatory determine whether to approve or
Authority, Inc.; Order Approving a disapprove the proposed rule change.
Proposed Rule Change Relating to The order was published for comment
SECURITIES AND EXCHANGE
Revisions to the Definitions of Non- in the Federal Register on October 7,
COMMISSION 2014.7 The Commission received
Public Arbitrator and Public Arbitrator
fourteen (14) comment letters in
[Release No. 34–74247A; File No. SR– February 26, 2015. response to the Proceedings Order.8 On
BATS–2015–09]
I. Introduction
Mass, dated July 21, 2014 (‘‘Mass Letter’’); Glenn S.
Self-Regulatory Organizations; BATS On June 17, 2014, the Financial Gitomer, McCausland Keen and Buckman, dated
Exchange, Inc.; Notice of Filing of a Industry Regulatory Authority, Inc. July 23, 2014 (‘‘Gitomer July Letter’’); David T.
Bellaire, Esq., Executive Vice President & General
Proposed Rule Change To Amend (‘‘FINRA’’) filed with the Securities and Counsel, Financial Services Institute, dated July 24,
Rules 11.9, 11.12, and 11.13 of BATS Exchange Commission (‘‘SEC’’ or 2014 (‘‘FSI Letter’’); Thomas J. Berthel, CEO, Berthel
Exchange, Inc.; Correction ‘‘Commission’’), pursuant to section Fisher & Company, dated July 24, 2014 (‘‘Berthel
19(b)(1) of the Securities Exchange Act Letter’’); Kevin M. Carroll, Managing Director and
February 26, 2015. Associate General Counsel, Securities Industry and
of 1934 (‘‘Act’’) 1 and Rule 19b–4 Financial Markets Association, dated July 24, 2014
AGENCY:Securities and Exchange thereunder,2 a proposed rule change to (‘‘SIFMA July Letter’’); CJ Croll, Student Intern,
Commission amend FINRA Rule 12100(p) of the Elissa Germaine, Supervising Attorney, and Jill I.
Code of Arbitration Procedure for Gross, Director, Investor Rights Clinic at Pace Law
ACTION: Notice; correction. School, dated July 24, 2014 (‘‘PIRC July Letter’’);
Customer Disputes (‘‘Customer Code’’) Jason Doss, President, Public Investors Arbitration
and FINRA Rule 13100(p) of the Code Bar Association, dated July 24, 2014 (‘‘PIABA
SUMMARY: The Securities and Exchange of Arbitration Procedure for Industry Letter’’); George H. Friedman, Esq., George H.
Commission published a document in Disputes (‘‘Industry Code’’) Friedman Consulting, LLC, dated July 24, 2014
(‘‘Friedman July Letter’’); Gary N. Hardiman, dated
the Federal Register on February 18, (collectively, ‘‘Codes’’), defining the July 24,2014 (‘‘Hardiman Letter’’); J. Burton
2015, concerning a Notice of Filing of a term ‘‘non-public arbitrator;’’ and LeBlanc, President, American Association for
Proposed Rule Change to Amend Rules FINRA Rule 12100(u) of the Customer Justice, dated July 24, 2014 (‘‘AAJ Letter’’); Richard
11.9, 11.12, and 11.13 of BATS Code and Rule 13100(u) of the Industry P. Ryder, Esq., President, Securities Arbitration
Commentator, Inc., dated July 24, 2014 (‘‘SAC July
Exchange, Inc.. The document Code, defining the term ‘‘public Letter’’); Andrea Seidt, President, North American
contained a typographical error. arbitrator.’’ Securities Administrators Association, and Ohio
The proposed rule change was Securities Commissioner, dated July 24, 2014
FOR FURTHER INFORMATION CONTACT: published for comment in the Federal (‘‘NASAA July Letter’’); Robert Getman, dated July
Christopher P. Grobbel, Division of Register on July 3, 2014.3 On August 4, 28, 2014 (‘‘Getman Letter’’); Barry D. Estell,
Attorney at Law (retired), dated August 13, 2014
Trading and Markets, Securities and 2014, FINRA extended the time period (‘‘Estell Letter’’); and Walter N. Vernon III, Esq.,
Exchange Commission, 100 F Street NE., in which the Commission must approve dated August 21, 2014 (‘‘Vernon Letter’’). Comment
Washington, DC 20549, (202) 551–5491. the proposed rule change, disapprove letters are available at www.sec.gov.
the proposed rule change, or institute The Commission discussed these comments in
Correction the Proceedings Order. See infra note 7.
proceedings to determine whether to 5 Letter from Margo A. Hassan, Assistant Chief

In the Federal Register of February approve or disapprove the proposed Counsel, FINRA Dispute Resolution, to Brent J.
18, 2015 in FR Doc. 2015–3222, on page rule change to October 1, 2014. The Fields, Secretary, SEC, dated September 30, 2014
8720, in the first and second line in the Commission received three hundred (‘‘FINRA September Letter’’). The FINRA September
sixteen (316) comment letters in Letter is available at www.sec.gov.
subheading under the heading 6 15 U.S.C. 78s(b)(2)(B).

‘‘SECURITIES AND EXCHANGE response to the Notice of Filing.4 On 7 Exchange Act Release No. 73277 (Oct. 1, 2014),

COMMISSION’’ in the third column, 79 FR 60556 (Oct. 7, 2014) (Order Instituting
1 15 U.S.C. 78s(b)(1). Proceedings To Determine Whether To Approve or
correct the reference to ‘‘File No. SR– 2 17 CFR 240.19b–4. Disapprove Proposed Rule Change Relating to
BATS–2014–09’’ instead to ‘‘File No. 3 Exchange Act Release No. 72491 (Jun. 27, 2014), Revisions to the Definitions of Non-Public
SR–BATS–2015–09.’’ 79 FR 38080 (Jul. 3, 2014) (Notice of Filing of Arbitrator and Public Arbitrator) (‘‘Proceedings
Proposed Rule Change Relating to Revisions to the Order’’). The comment period closed on November
Jill M. Peterson, Definitions of Non-Public Arbitrator and Public 6, 2014.
Arbitrator) (‘‘Notice of Filing’’). The comment 8 The comment letters were submitted by: John A.
Assistant Secretary. period closed on July 24, 2014. Bender, Esq., Member, Ryan Swanson Cleveland,
[FR Doc. 2015–04423 Filed 3–3–15; 8:45 am] 4 Of the 316 letters, 21 were unique letters, and dated October 10, 2014 (‘‘Bender Letter’’); George H.
BILLING CODE 8011–01–P 295 of the letters followed a form designated as the Friedman, Esquire, George H. Friedman Consulting,
‘‘Type A’’ letter, submitted by self-identified LLC, dated October 20, 2014 (‘‘Friedman October
independent financial advisors (‘‘independent Letter’’); Richard P. Ryder, Esq., President,
financial advisors’’) (‘‘Type A Letter’’). The unique Securities Arbitration Commentator, Inc., dated
letters were submitted by: Philip M. Aidikoff, October 26, 2014 (‘‘SAC October Letter’’); Steven B.
Aidikoff, Uhl & Bakhtiari, dated July 1, 2014 Caruso, Esq., Maddox Hargett & Caruso, P.C., dated
mstockstill on DSK4VPTVN1PROD with NOTICES

(‘‘Aidikoff Letter’’); Steven B. Caruso, Esq., Maddox October 29, 2014 (‘‘Caruso October Letter’’); Ryan
Hargett & Caruso, P.C., dated July 1, 2014 (‘‘Caruso K. Bakhtiari, Aidikoff, Uhl & Bakhtiari, dated
July Letter’’); Ryan K. Bakhtiari, Aidikoff, Uhl & October 30, 2014 (‘‘Bakhtiari October Letter’’);
Bakhtiari, dated July 2, 2014 (‘‘Bakhtiari July Glenn S. Gitomer, McCausland Keen and Buckman,
Letter’’); Richard A. Stephens, Attorney at Law, dated November 5, 2014 (‘‘Gitomer November
dated July 6, 2014 (‘‘Stephens Letter’’); Daniel E. Letter’’); William Beatty, President, North American
Bacine, Barrack, Rodos & Bacine, dated July 18, Securities Administrators Association and
2014 (‘‘Bacine Letter’’); Blossom Nicinski, dated Washington Securities Administrator, dated
July 20, 2014 (‘‘Nicinski Letter’’); Christopher L. Continued

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Document Created: 2018-02-21 09:31:45
Document Modified: 2018-02-21 09:31:45
Category		Regulatory Information
Collection		Federal Register
sudoc Class		AE 2.7: GS 4.107: AE 2.106:
Publisher		Office of the Federal Register, National Archives and Records Administration
Section		Notices
Action		Policy revision; issuance.
Dates		This revision to the Enforcement Policy is effective March 4, 2015.
Contact		Daniel Lenehan, telephone: 301-415- 3501, email: [email protected], or Shahram Ghasemian, telephone: 301-415-3591, email: [email protected]; both of the Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555- 0001.
FR Citation		80 FR 11693