ML20086M824

Comment on Proposed Review of NRC Insp Rept Content,Format & Style

ML20086M824
Person / Time
Site:	Davis Besse
Issue date:	06/29/1995
From:	Stetz J CENTERIOR ENERGY
To:	Meyers D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR28180, RULE-PR-MISC 60FR28180-00020, 60FR28180-20, NUDOCS 9507250015
Download: ML20086M824 (4)

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United States Nuclear Regulatory Commission Office of Administration Vashington, D. C. 20555 Attention: Mr. David Myers, Chief, Rules Review and Directives Branch, Division of Freedom of Information and Publication Services

Subject:

Comments on Review of NRC Inspection Report Content. Format, and Style (60 FR 28180)

Gentlemen:

Toledo Edison (TE), a subsidiary of Centerior Energy, is partial owner of and is responsible for operation of the Davis-Besse Nuclear Power Station (DBNPS). Toledo Edison has been authorized for power operation of the DBNPS since April 1977. As a 10 CFR 50 licensee, TE has a vested interest in any policies the Nuclear Regulatory Commission (NRC) may adopt which can affect the management and operation of a commercial nuclear power plant.

Tcledo Edison has reviewed the subject Federal Register notice and submits the following comments for consideration.

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1. Inspection Report Content l l

Changes to the content of inspection reports should be I coordinated through the NRC/ Nuclear Energy Institute (NEI) vorking group dealing with management of NRC commitments. This vould be beneficial for a number of reasons, notably-in the area of determining the safety significance of issues discussed in inspection reports. In guidance proposed by NEI on management of NRC commitments, the ease of changing or modifying a commitment is determined largely by the safety significance of the issue involved. In the past, the safety significance of an issue has 9507250015 950629 PDR ADOCK 05000346 H l 3 PDR Operating Companies Cleveland Electnc liluminating Toledo Edison

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not always been clearly articulated in inspection reports and changing or modifying the commitments associated with these i issues may prove to be difficult. By clearly establishing the j safety significance of an issue up front, significant resources could be saved in the future should commitments need to be changed or modified.

The opinions of individual inspectors in inspection reports )

should be minimized and, in cases where they are deemed i necessary to be included, should be clearly identified as the l inspector's opinion. Inspection exit meetings are the forum in I which these issues should be discussed. For example, if an l inspector finds a licensee's process burdensome or confusing, j but the process meets the applicable regulatory requirements and j commitments, the inspector's opinion of the process is not relevant. Licensees invite inspectors to express their opinions on matters of this nature during exit meetings, however, voicing personal opinions in a public document, such as an inspection report, gives the public the impression that the inspector's opinion is that of the NRC and these opinions assume the status of regulation.

Along the same line, detailed discussions of strengths and weaknesses in inspection reports serve little purpose. Although I licensees velcome these discussions during inspections and exit I meetings, including details in the inspection reports is not necessary. Inspection report discussions should be limited to .- )

the assessments of a licensee's ability to meet regulatory l requirements. Also, weaknesses identified in inspection reports I are perceived by licensees as issues that require specific l I

corrective actions. Inspectors often expect specific corrective actions for identified weaknesses and may view a licensee that has not taken specific corrective actions to alleviate a weakness as uncooperative.

Detailed discussions of circumstances surrounding Licensee Event Reports (LERs) that have been submitted by a licensee are also I unnecessary, unless additional information is presented by the )

inspector. In these cases, the LER should merely be referenced )

and any additional information presented. This vill eliminate any potential conflicts in event descriptions, causes, or corrective actions between LERs and inspections reports.

2. Inspection Report Format Inspection reports should be of consistent format, not only within the Region, but from Region to Region. This vould enable more accurate comparisons of plants' performance and facilitate more meaningful dissemination of NRC concerns by the industry.

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. Docket Numbar 50-346 License Number NPF-3 Serial Number 2306 Page 3 Toledo Edison has also noted inconsistencies between inspection reports issued from different divisions within the Region.

Toledo Edison encourages the NRC to adopt the integrated inspection report concept as a method to provide the needed consistency. Alternatively, if separate inspection reports are retained, TE suggests that an appropriately senior level of NRC management be responsible for inspection report content such that consistent themes and concerns are more clearly communicated to licensees.

"Bulletized" formats are preferred, especially when discussing such items as observations, strengths, weaknesses, commitments, and closure of previously identified concerns. Lengthy ,

discussions of these items merely serve to increase the volume '

of inspection reports and provide little useful information as I this information should have been discussed with licensee management during the inspection or at the inspection exit meeting.

Commitments made by licensees during the course of an inspection should be more clearly identified as such in inspection reports.

It would be preferred that they be assigned tracking numbers in I a manner similar to open and unresolved items. It is also l suggested that such commitments be summarized in the report in a l "bulletized" format. This practice vill result in ease of tracking commitments on the part of both the NRC and licensees, and vill also minimize the possibility of niisunderstandings of NRC expectations in resolving the associated issues. Many ,

licensees have adopted the practice of summarizing commitments l made in docketed correspondence and have found it benefits both the NRC and the licensees in future interactions.

The content of inspection report cover letters, as is the case with the comment on inspection reports above, should be free of unsupported opinions. If an area of concern exists, it should be clearly supported by factual findings in the inspection report. The NRC should be vigilant against making broad generalizations regarding the adequacy of licensee management based upon limited factual information. Also, these areas of concern should be clearly communicated orally to the licensee, either during the inspection exit meeting or in subsequent conversations, prior to issuance of the inspection report.

Comments on licensees' performance in cover letters should contain no surprises or subtle messages. This practice only hinders communication between licensees and the NRC.

Internal licensee documents such as procedures, calculations or independent studies should not be included as attachments to inspection reports. These documents are available for inspector review but are not subject to public disclosure unless they are formal?y docketed by the licensee.

, Docket Number 50-346 License Number NPF-3 Ser'ial Number 2306 Page 4

3. Inspection Report Style Variations in writing style between NRC inspectors make interpretation of licensee commitments difficult. Phrases such as "the licensee intends to...", "the licensee is evaluating...", or "the licensee is considering..." in the context of discussions of licensee responses to issues identified by inspectors should be avoided. Instead, more concise words and phrases should be used, such as "the licensee committed to..." or "the licensee vill...". This will minimize confusion in identifying any licensee commitments documented in inspection reports.

4. Additional Comments In several instances, TE has been requested to respond to weaknesses identified in inspection reports (

Reference:

NRC Inspection Reports 50-346/93016 and 50-346/94016). Although not explicitly stated, the purpose of these requests was to ask that TE provide commitments to correct weaknesses, even though no items of noncompliance vere identified. This practice seems to conflict with Subpart B of 10 CFR 2, as these " requests" were effectively " Demands for Information". In the future, this practice should be discontinued and the NRC should use existing regulatory mechanisms to obtain additional information to ensure l compliance with the regulations.

Should you have any questions or require additional information, please contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.

Very truly yours,

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NK / d cc: L. L. Gundrum, NRC Project Manager J. B. Hartin, Regional Administrator, NRC Region III V. H. Rasin, Nuclear Energy Institute S. Stasek, DB-1 NRC Senior Resident Inspector USNRC Document Control Desk Utility Radiological Safety Board

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