ML20005G815
| ML20005G815 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/1990 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NRRL-1100, NUDOCS 9001230131 | |
| Download: ML20005G815 (8) | |
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- UNITED STATES J
NUCLEAR REGULATORY COMMISSION o
g i) wash NoToN,D.C 20665 pf January 8, 1990 1
llEMORANDUM FOR:
All NRR Employees L
FROM:
Thomas E. Murley,IDirector Office of Nuclear Reactor Regulation
SUBJECT:
IIRR OFFICE LETTER'NO. 1100 - PROCESSING OF INSPECTION REPORTS I;
PURPOSE This office letter provides instructions on the processing of inspection-i.
L reports for those inspections for which NRR is the lead office.
OBJECTIVES l
The objectives of this office letter are-to provide for a record of concur-rences in the issuance of inspection. reports prepared by NRR, to describe how
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differences and substantive changes'are h6ndled as inspection reports proceed
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~through the concurrence chain, and to prescribe who signs inspection reports.
L BACKGROUND _
NRR inspections of Comanche Peak and.TVA facilities are conducted by-theistaff of tile Associate Director for Special Projects (ADSP). All other NRR inspec-.
tions'are conducted by the Division of Reactor Inspection andl Safeguards (DRIS).
Employees of other NRR divisions who conduct: inspections, either singly or as a member of an NRR inspection team,- are considered to have been detailed to DRIS for the performance of the inspection and the preparation of the inspection c
L report.
i l
All inspections must be performed in accordance with the NRC-. Inspection Manual, particularly those procedures in the '2500 series, " Reactor Inspection Program,"
and the 2700 series, " Licensee Contractor and Vendor Inspection Program."
Inspection Manual Chapter (IMC) 0610, " Inspection Reports," contains require-ments'and guidance for the preparation of a11' inspection reports.
RESPONSIBILITIES AND AUTHORITIES-Director. Division of Reactor Inspection and Safeguards (DRIS)
Except for those inspections conducted and reports prepared under the'juris-diction of ADSP, Is responsible for the content and conclusions in NRR inspection reports, k\\
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-9001230131 90olos
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All NRR Employees
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January 8, 1990 b.
Resolves differences among participating inspectors and supervisors re-l garding' inspection report content and conclusions that could not be l
resolved at lower management levels for NRR inspections, c.
Forwards reports of NRR inspections of licensees to the appropriate Division of Reactor Projects for issuance to_the licensee.-
t d.
Informs the Director of the appropriate Division of Reactor Projects of concerns raised by participating inspectors that have caused an inspector l-to deny concurrence on the issuance of an inspection report.
e.
Authorizes the issuance of reports of inspections at vendor sites-not
- related to a specific licensee.. (May delegate.to Chief, Vendor Inspec-tionBranch.)
l Directors, Other Technical Divisions, NRR Concur or comment on technical issues raised in inspection reports when re-quested to do so by DRIS.
Directors, Division of Reactor Projects-Transmit reports of NRR team inspections to the licensee.
Inspection Team Leader and the Lead Inspector The inspection team leaoer, for team inspections, or the lead inspector, for other inspections, is responsible for b.
Compiling the input from participating inspectors and' contractors into an inspection report consistent with the requirements-and guidance of IMC 0610.
b.
Ensuring that substantive changes to a participating inspector!s report input are discussed with the originating inspector and any significant disagreements are either resolved or directed to the' appropriate level of DRIS management for a decision regarding report content, c.
Coordinating inspection findings and proposed enforcement actions with the appropriate regional office division.
t l
participating Inspectors i
Participating inspectors are responsible and accountable for assuring that (1) their inspection report input accurately represents the scope and results.of their examinations, and findings are supported by sufficient factual informa-tion'to allow the reader to understand the issue; and (2) the' technical and regulatory substance of their inspection work is reasonably represented in the inspection report as submitted by the team leader or lead inspector to the responsible DRIS branch chief for approval.
If this is not the case, then the l
inspector is. responsible for bringing the issue to the attention of the respon-sible DRIS section chief, then to the responsible DRIS branch chief and, if necessary, to the Director, DRIS, for resolution.
w All NRR Employees January 8, 1990
~ Associate Director for Special Projects (ADSP)
For inspections of Comanche Peak and TVA under the jurisdiction of ADSP, direc-tors, inspection team leaders, lead inspectors, and participating inspectors:
have the same responsibilities and authorities as the corresponding individu-als in DRIS previously described.- In addition, inspection reports are proc-essed within ADSP in accordance with the basic requirements and are issued by ADSP.
BASIC REQUIREMENTS Some steps in the process of preparing and issuing inspection reports refer to DRIS supervisors and managers. For ADSP inspections, these steps refer to ADSP supervisors and managers.
General When issued, the inspection report must be an NRC product based on the pro-fessional work of the participating inspectors and documented by the teau leader or the lead inspector, who coordinates the input from the participating inspectors. The team leader or the lead inspector shall ensure that the report l
1s consistent with current standards and practices in style, there.is an-ade-quate factual basis for the findings, the technical informatinn is complete.
l and the safety importance and regulatory basis for the findings are stated in l
sufficient detail to support the appropriate regulatory action.
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l In accordance with NRR Office Letter No. 102, " Policy on Placing Documents in
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L the Document Control System (DCS), the Central Files, and the Public Document 1
Room (PDR)," inspection reports and related correspondence should be sent to-the DCS, Central Files..and, as appropriate, the PDR.
External distribution of inspection reports and related correspondence to licensees should be consistent with distribution by the regional office to that licensee.
If necessary, con-tact the regional office to identify any special distribution.
Internal dis,
I tribution is made through the Regulatory Information Distribution System (RIDS) using Distribution Code IE01 for reactor licensees, Code'IE09 for vendor in-spections, or another appropriate distribution code.. For assistance in select-ing and using distribution codes, contact the Administration Section, Planning, Program & Management Support Branch.
' Initial Processino of Inspection Reports Each participating inspector prepares his or her input to the inspection-report in accordance with INC 0610 and provides this input to the team leader-or the lead inspector.
. The team leader or lead inspector is responsib'le for preparing the inspection report, including resolution of all substantive concerns raised by the partic-ipating inspectors regarding report content. The participating inspectors are l
responsible for the report, including directing any report content issues they believe have not been resolved satisfactorily to the appropriate management for resolution.
The completed inspection report is reviewed by first-level supervisors, usually the responsible DRIS section chief.
In addition, the team leader or the lead t
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1 All NRR Employees -
January 8,1990 inspector cocrdinates the inspection results with the regional office to permit l
assessment of any impact on current inspections and enforcement items. After review, the inspection report is approved and signed by DRIS nanagement, usually the responsible DRIS branch chief.
For vendor inspection reports not-related to a specific licensee, the responsible DRIS section chief normally approves the report.
Signatures on Inspection Reports The team leader or the lead inspector signs the inspection report. All-partic-ipating inspectors and contractors are listed on.the inspection report cover i
page. The supervisor who approved the report also signs the-inspection repart l
cover page.
If another individual reviewed the report for technical and regu-latory considerations, that individual may also sign the inspection report cover page and note the function performed.
In those instances in which a lead inspector is not assigned, all participating' inspectors should sign the report.
Inspection reports that describe substantive problems (e.g., matters for which-escalated enforcement action may be considered, findings of multiple weaknesses in a licensee program or activity, multiple violations) are concurred in by the Director, DRIS.
Record cf Concurrence For each inspection report prepared by DRIS there must be a record of concur-rence by participating inspectors. Such concurrence indicates agreement with the technical content of that part of the inspection report prepared by the concurring individual. See also NRR Office Letter No. 101, " Delegation of L
Signature Authority," as revised, for further discussion of the meaning of concurrence. The tean leader, the lead inspector, or. another knowleogeable inspector may concur for an inspector who is absent when:the final report is processed. Telephone concurrence is acceptable when it is necessary to docu-ment an absent inspector's agreement with substantive revisions that may change the intent or a significant technical fact of the original report input.
Concurrence in the contents of the inspection report is recorded as.follows:
For vendor inspections, the Chief, Vendor Inspection Branch, normally signs the transmittal letter to the vendor. All participating inspectors are included in the concurrence chain of the transmittal letter. -When escalated enforcement action is taken, the letter to the~ vendor is signed by the Director, DRIS, or the Associate Director for Inspection and Tech-nical Assessment and includes concurrence by the EDO and the Office of Enforcement in addition to that of the participating inspectors. See NRR Office Letter No. 101, as revised.
For NRR team inspections of licensees, DRIS prepares the transmittal letter to the licensee for the signature of the Director of the appro-priate Division of Reactor Projects. All participating inspectors, the responsible DRIS branch chief, and the Director, DRIS, are included in the concurrence chain. Other technical divisions should be included in the concurrence chain when technical issues for which prior review was re-quested are discussed in the report. The Director, DRIS, informs the Director of the appropriate Division of Reactor Projects of any substan-tive differences raised by a participating inspector who elected not to concur and management's resolution of such differences.
e t
All NRR Employees 5
-January 8, 1990 l
l Substantive Changes Made'to Inspection Reports As an inspection report progresses through review and issuance, changes may be made to the report. Care must be taken to ensure that the factual content has not been materially changed without the knowledge of the originator, who in.
most cases is a participating inspector. As a minimum, substantive changes shall be discussed with the inspector to ensure that the inspector still i
concurs in the factual content of the report.
If the inspector does not agree with the changes or some compromise, the inspector may seek review of the matter from successively higher levels of DRIS management up to the Director, DRIS.
If the inspector still does not agree with the inspection report contents, the inspector may choose not to concur in the document that transmits the i
l report.
In such cases, the inspector shall document his or her reasons for nonconcurrence and a management representative shall document the reasons for proceeding without the inspector's concurrence.
EFFECTIVE DATE i
l This office letter is effective immediately.
Origini sised by Thomas E. Murley, Director l
Office of Nuclear Reactor Regulation l
cc:
J. Taylor, ED0 W. Russell, Region 1 H. Thompson, DEDS S. Ebneter, Region II J. Aments, IRM A.' Davis, Region Ill l
SECY R. Martin, Region IV OGC J. Martin, Region V NRC PDR Distribution:
I Central Files ILPB RF NOTE NRC PDR PMAS RF i
H. Smith (Original & 5 copies)
- 1. The Technical Editor reviewed this R. Paulus office letter on 11/22/89.
M. Peranich E. Butcher
- 2. The proposed office letter was V. Wilson was reviewed by l
1 J. Larkins the NRR Division Directors.
F. Gillespie T. Hurley
- SEE PREVIOUS CONCURRENCE
- 0FC
- IPDS/ILPB
- C/IPDS/ILPB :C/ILPB/PMAS :ADM/PMSB
- C/ADM/PMSB
- C/PM5B/PMAS :
j lNAME :RPaulus*
- MPeranich* :EButcher*
- HSmith*
- VWilson*
- JLarkins*
lDATE :11/22/89
- 11/22/89
- 11/22/89
- 11/29/89
- 11/
/89
- 11/
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'DATE :12/
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- 12/
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- 1/
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- 1/ 3 /90
-OFFICIAL RECORD COPY Document Name: REVISED OL 1100
3 All>NRR Employees !
Substantive' Changes Made to Inspection Reports As an inspection report progresses through review and issuance, changes may be made to the report. Care must be_ taken to ensure that the factual content has i
l-notbeenmateriallychangedwithouttheknowledgeoftheoriginator,whoin l
most cases is a' participating inspector.
As a minimum, substantive changes shall be discussed with the. Inspector to ensure that the ifispector still l
concurs in the factual content of the report.
If the ins'pector does not agree i
with' the changes or some compromise the inspector may, seek review of the matter i
1 from successively higher levels of DRIS management up,,to the Director, DRIS.
l If the inspector still does not agree with the insp,elction report contents,-
the inspector may choose not to concur in the document that transmits the report.
In such cases, the inspector shall documsnt his or her reasons for l
nonconcurrence and a management representative shall document the reasons for proceeding without the inspector's concurrence /
EFFECTIVE DATE This office letter is effective immediate l
l Thomas E. Murley, Director i
Of,fice of Nuclear Reactor Regulation 1
/
cc:
J. Taylor, ED0 W. Russell, Region I i
I H. Thompson, DEDS
/S.Ebneter,RegionII l
J. Amenta, IRM A. Davis, Region III l
SECY R. Martin, Region IV i
i OGC J. Martin, Region V l
NRC PDR Distribution:
VCentral Files ILPB RF NOTE NRC PDR PMAS RF
-i H. Smith (Original & 5 cop es)
- 1. The Technical. Editor reviewed this R. Paulus office letter on-11/22/89.
M. Peranich f
E. Butcher
- 2. The proposed office letter was V. Wilson was reviewed by J. Larkins.
the NRR Division Directors.
F. Gillespie T. Murley
- SEE PREVIOUS CONCURRENCE OFC :lPD5/ILPB
- C/IPDS/l
- C/ADM/PMSB :C/PMSB/PMAS :
.....:............:________f..B:C/ILPB/PMAS:ADM/PMSB
- NAME :RPaulus*
- MPeran1[h*:EButcher*
- HSmith*
- VWilson*
- JLarkins*
DATE :11/22/89
- 11/22/d9 t:11/22/89
- 11/29/89
- 11/
/89
- 11/
/89
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DATE:12/%/89
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B All NRR Employees
- i Substantive Changes Made to Inspection Reports As an inspection report progresses through review and issuance, changes may be-made to the report. Care must be taken to ensure that the factual content has not been materially changed without the concurrence of the originator, who in most cases is a participating inspector. As a minimum, substantive changes shall be discussed with the inspector to ensure that the inspector still concurs in the factual content of the report.
If the inspector does not agree 1
with the changes or some compromise, the inspector may seekkeview of the matter from successively higher levels of DRIS management up to th'e Director, DRIS.
/
If the inspector still does not agree with the inspect, ion report contents, the inspector may choose not to concur in the document that transmits the report.
In such cases, the inspector shall document'his or her reasons for nonconcurrence and a management representative shall document the reasons for proceeding without the inspector's concurrence.
EFFECTIVE DATE
/
This office letter is effective immediately/
/
/
/
Thomas E. Murley, Director O fice of Nuclear Reactor Regulation cc:
J. Taylor, ED0
/W. Russell, Region I H. Thompson, DEDS j/ S. Ebneter, Region II J. Amenta, IRM A. Davis, Region III SECY
/
R. Martin, Region IV' OGC
/
J. Martin, Region V NRC PDR
/
i Distribution:
/
i Central Files ILPB RF NOTE NRC PDR PMAS RF f
H. Smith (Original & 5 copies)
- 1. The Technical Editor reviewed this R. Paulus office letter on 11/22/89.
M. Peranich E. Butcher
- 2. The proposed office letter was V. Wilson f
was reviewed by J. Larkins the NRR Division Directors.
F. Gillespie T. Murley SEE PREVIOUS CONCURRENCE i
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DATE :11/22/89
- 11/22/89
- 11/22/89
- 11/29/89
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- D/NRR NAME :FGillespie :FMiraglia
- TMurley DATE :11/
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- 11/
/89
- 11/
/89 0FFICIAL RECORD COPY I
L Document Name: REVISED OL 1100
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5 not been materially changed without the concurrence of the origi. or, who in most cases is a participating inspector. As a minimum, substan ve changes shall be discussed with the inspector to ensure that the.insp tor still concurs in the factual content of the report.
If the inspe or does not agree with the changes or some compromise, the inspector may see review of the-1 matter from successively higher levels of DRIS managemen up to the Director, DRIS.
If the inspector still docs not agree with the insp tion report contents, the inspector may choose not to concur in the doc,ent that transmits-the report.
In such cases, the inspector shall'docu nt his or her reasons for nonconcurrence and a management representative hall document the reasons for_
f proceeding without the inspector's concurrenc.
EFFECTIVE DATE This office letter is effective immedi ely, homas E. Nurley, Director Office of Nuclear Reactor Regulation cc:
J. Taylor, ED0 W. Russell, Region I H. Thompson, EDES S. Ebneter, Region II J. Amenta, IRM A. Davis, Region III SECY R. Martin, Region IV OGC J. Martin, Region V NRC PDR Distribution:
Central FiTes NOTE NRC PDR H. Smith (Origip 1 & 5 copies)
- 1. The Technical Editor reviewed this l
R. Paulus.
/
office letter on 11/22/89.
M. Peranich E. Butcher
- 2. The proposed office letter was V. Wilson was reviewed by J. Larkin the NRR Division Directors.
F. Gille pie T. Hurl y ILPB Rr PMAS IF
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- DATE :11/pA/89
- 11/fA/89
- 11/At/89~
- 11/h-/89
-:11/
/89
- 11/
/89 i0FC _:D/PMAS
- ADT/NRR
- D/NRR
!NAME :FGillespie :FHiraglia
- TMurley lDATE :11/
/89
- 11/
/89
- 11/- /89 OFFICIAL RECORD COPY Document Name: REVISED OL 1100 w