As part of its broad investigation of Tennessee athletics, the NCAA is looking into whether former Vols assistant head coach and recruiting coordinator Ed Orgeron personally conducted a workout of a prospective signee on the student's campus in May 2009, three sources told ESPN.

"When we went through some stuff about Tennessee, I've been told that I'm not allowed to comment," Orgeron, now the defensive coordinator and recruiting coordinator at USC, said Friday. "That's what I've been instructed to do. That's what I'm doing."

The prospect, Brandon Willis of Byrnes (S.C.) High, became the No. 10 rated defensive lineman in the Class of 2010 (No. 110 in the ESPNU 150). Byrnes athletic director Bobby Bentley said the NCAA is investigating the charge. "I don't think it would be for me to say anything," he said.

NCAA rules allow college coaches to observe a prospect twice during the spring of his junior year. However, the college coach may not instruct the prospect or conduct the workout. The NCAA doesn't allow in-person contact between a college coach and a prospect off the college campus until a six-week period that begins after Thanksgiving of the prospect's senior year of high school.

The recruiting calendar is clear and well understood in the coaching community. The evaluation rule, sometimes referred to as the "no-tryout" rule, is clear, too. Unlike some portions of the NCAA manual, there is no gray area regarding either potential violation. Orgeron, two sources said, conducted the workout of Willis at 6 a.m.

The NCAA likely would consider the case a secondary violation rather than a major one, with penalties that may include a reduction in off-campus recruiting days by the coaching staff and a reduction in official visits by high school prospects. Among the mitigating factors in determining the severity of the violation would be whether the NCAA finds a pattern of behavior and how much of a recruiting advantage the university gained from the violation.

Willis, in fact, did commit to Tennessee on Jan. 9, 2010, his senior year. Three days later, the day before Willis planned to enroll at Tennessee, Volunteer head coach Lane Kiffin left for USC, taking Orgeron with him. Willis promptly enrolled at North Carolina and played in the spring game last April.

However, last September, because of personal hardship, North Carolina granted Willis a release so that he could transfer to UCLA, the archrival of Orgeron's new school.

AOL Fanhouse reported earlier this week that the NCAA would cite the Tennessee program and Kiffin with a failure to monitor violation during Kiffin's one-year tenure at the school.

Ivan Maisel is a senior writer for ESPN.com.