ML20238A548
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{{#Wiki_filter:.-_._.. CPAWG -8 JAN 9 1987 c > f.vg MEMORANDUM FOR: John G. Davis, Director Of fice of Nuclear Material Safety and Safeguards FRCMt Rooert D. Martin Regional Administrator
SUBJECT:
INFORMATION FOR COMANCHE PEAK OIA REPORT 86-10 REVIEW GROUP--RG RIV-02 This memorandum provides the information you requested in your draft memo-rancum, same subject, and covers inspection reporting, item identification, classification anc disposition, and inscector responsibilities. Copies of RIV documentation referenced in the enclosed responses are also included. When we refer to IE-originated documentation sucn as Manuals, Tradning Handouts, etc.. we assume that tnese will be furnished oy OIE in response to Tast RG IE-02. Generally available material, e.g., NRC Manual, r.as not been provided. Shoulo you require additienal information or elaboration of the informa*. ion provided, please feel f ree to contact either R. E. Hall (FT5 728-8182) or me. / w 'N Robert D. Martir Regional Administrator Enf.osure: Re:ponses to CPRRG Information Reouests wi th Attachments cc: w/ Enclosure Taylor, IE a. 7 s,:'1 i 8708210007 870312 PDR ADOCK 05000445 0 PDR l 1 I
f / Enclosure 1 RESPONSES TO CPRRG INFORMATION. REQUEST INFORMATION REQUEST 1. Information--regardless by whoin developed-which establishes the responsibilities of the inspector, supervision, and management with regard to inspection performance, reporting, review and concurrence on reports and i meaning and responsibilities of signatures and concurrences.
RESPONSE
1.1 The IE Manual is the principal source of information defining the responsibilities of the inspector, supervision and management. Those specific manual chapters applicable to in Dection performance, and reporting are listed below: r 0215 NRC Inspector Objectivity 0235 Concuct of Employees 0237 Supplemental Statement on Conotet of Employees for hesident Inspectors 0300 Unannounced Inspections 0400 Enforcement Program 0610 Inspection Reports i 0801 Inspector Feedback 1245 Inspector Qualifications 2500 Reactor Inspection Program (Includes MCs 2511, Pre-CP Phase; 2512, Construction Phase: 2513, Preoperational Test Phase; 2514, Startup Testing Phase: 2515, Operations Phase; and by reference, all inspection modules applicable to each phase of the inspection program.) 9900 Guidance (Provides interpretative guidance in the areas of Regulatory Guides, Codes and Standards, Standard Technical Specifications and the Code of Federal Regulations) 4
l ( l.2 Specific training on the topics of inspection performance, reporting, and documentation of inspection activities has been provided by IE in the course identified as G-101, " Fundamentals of Inspection." This course utilizes .a text entitled " Inspector's Manual;" a copy of the manual is provided for each course participant s use and retention. Sections of the " Inspector's j 4 Manual" pert nent to the areas of inspection performance, reporting, and j documentation include: i The Mission of the Office of Inspection and Enforcement Legal Aspects of Inspection i How to Prepare For an Inspection How to Perform an Inspection Involving Documentation Review and Observation of Werk Activities Effective Communication During the Conduct of an Inspection Identifying Appropriate Legal Commitments and Requirements for Enforcement Action Handling of Safety Related Matters Not Covered by Requirements or Commitments Personal Conduct of Inspectors ( I 1.3 Regional Office Policy Guides (ROPGs) have been issued to araplify or emphasize the program office and NRC requirements. A listing of those R0PGs which f all in tnis categcry is provided in answer to Information Request No. 6 below, Copies of each ROPG are either provided in response to specific Information Requests below, or in Attachment 6. 1.4 Continuing regional training by supervision is provided in formal training sessions. Examples of training sessions of this type during the past year have included: Coce of Federal Regulations (Applicable Parts) Codes and Standards Notice of Violations Radiation Protection Ecual Employment Opportunity l Administrative Practices and Procedures Drug and Alcohol Abuse Train the Trainer i Emergency Response a
l ~ Operational Events (. FOIA Search Requirements ~ Enforcement Policy Allegations Management Specific Technical Subjects Conflict of Interest Legal Aspects of Inspection Disposition of Inspection Findings Performance Indicators l Enforcement Issues Documentation of Violations l Copies of two typical training calendars are included in Appendix 1.A. 1.5 Informal training is also provided on a continuing basis by interactions between the inspector and his supervision. This training is undocumented. 1.6 Resident inspector Seminars are held periodically. For selected topics, attendance of not only the Resident I'nspectors, but also available Regional (region based) Inspectors is either strongly encouraged or mandatory. Copies of the two most recent Resident Inspector Seminar Agendas are included in.A. i 1.7 Policy guicance on the review and concurrence on reports and the meaning and responsibilities of signatures and concurrences has been developed and provided in Regional Office Policy Guide (ROPG) 0220, " Meaning of Concurrence." A copy of R0PG is appended as attachment 1.B. Prior to issuance of the initial version of R0PG 0220, guidance was often provided by directive memoranda to respective staffs. Appenoed as attachments 1 C and 1.0 are two 2 examples of this type of guidance which were retrievable. l 1 3 4 )
...... - ~... - l I 1 \\ j 1NFORMAf10N RE0 VEST '( 2. Information used by Region IV which identifies means to resolve differences of opinions or positions with regard to inspector performance l information, recommendations, and Region IV report content. { l Following discussion with the CPRRG (R. A. Erickson), we restate this to read: 2. Information used by Region IV which identifies means to resolve differences of opinions or positions with regard to inspection performance and { ) report content.
RESPONSE
2.1 The principal guidance used by Region IV historically has been NRC Manual Chapter 4125, " Differing Professional Opinions;" however, since use of the DP0 option by an employee is optional, only seldom has it been used by Region IV inspectors as an avenue for resolution of differences. 2.0 The incidence of differing opinions between inspectors and their supervisors and managers in Region IV has been very low. Inspector interfaces with peers and supervisors have normally led to a common understanding of findings, their significance, and the appropriate means of obtaining corrective actions for adverse findings. Two notable exceptions come to mind:
- 1) the instant care involving Comanche Peak, and 2) tne South Texas special inspection documented as inspection report 50-498/499 / 79-19. In the South Texas case, IE mediation of several issues was necessary because of differit.g professional opinions oetween inspector peers, and supervisors and inspectors.
2.3 As the Comanche Peak case developed, we became increasingly aware that the DP0 process wouldn't work because the process was optional and employees with problems would not activate the process for fear of reprisal. It was apparent to us, then, that if we were to be successful in resolving ] cif ferences between supervisor and supervised, we needed a device permitting i us to control the situation by requiring issue resolution. { To alleviate the possible misconception of the desirability of use of NRC MC 4125, regional guidance in the form of R0PG 2201, " Disposition of Inspection Findings," has been issued. A copy of R0PG 2201 is appended as..A. This policy guide discusses the definite expectation of regional management that all issues will be properly resolved, and that the provisions of NRC MC 4125 will De followed in cases of residual inspector concern over disposition of inspection findings. Training sessions have been conducted within the past year on ROPG 2201 for URF0 staff, for Regional l inspection staff, and for the Resident inspectors. Additionally, as discussed l in the first topic, R0PG 0220 " Meaning of Concurrences," has also been revised to provide the avenue for documenting differences of opinions between staff at l all level:. who have difficulty in concurring with f ormal documentation. A copy of ROPG 0220 is incluoed as Attachment 1.B, along with a copy of viewgraphs used for training classes on this Policy Guide. 4 4 l l I I 1
INFORMATION Rt0Ut5lE0 j ~ ~ 3. Information that describes the possible classifications of findings or conclusions from reports (changed to inspections by CPRRG) and the meaning of the classifications in terms of safety significance, " attention" or Regional follow-up given to items because of classifications, conclusions regarding licensee performance, and enforcement. What the CPRRG seeks is information used oy Region IV staff that identifies the significance of differences in classification of items or findings from inspections. The CPRRG is*especially interested in distinguishing between differences based on procedural requirements from those based on safety concerns and whether such differences result in different regional handling and follow-up actions.
RESPONSE
3.1 The primary ano essentially universal guidance for classification of findings from inspections used by Region IV is Appendix C to 10 CFR 2, and specifically the Supplements to Appendix C These supplements provide the basis for classification of violations in terms of safety significance, and directly relate to resultant enforcement action. 3.2 IE MC 0400 and its precursors provide the specific procedures for preparation of enforcement action and for classification of inspection findings into Violations, Deviations, Unresolvec Items, and acceptable findings. Examples are provided which depict the differences in classi-fications, and each classification is explicitly defined. IE MC 0610 also describes the method of documenting inspection findings based on their ~ classification. c j -5 3 3.3 The Fundamentals of Inspection Training Manual discussed in the first Information Request above specifically identifies the methods for defining and handling inspection findings in the following sections of the Manual: How to Perform an Inspection Involving Documentation Review and Observation of Work Activities Effective Communication During the Conduct of an Inspection Identifying Appropriate Legal Commitments and Requirements for Enforcement Action Handling of Safety Related Matters Not Covered by Requirements or ) Commitments l I l ( l 1 l l
( 3.4 R0PG 0102, " Communications Regarding Items of Immediate Interest," which ~ was issued primarily for the Division of Radiation' Safety and Safeguards, reflects general regional policy regarding immediate escalation of information regarding inspection findings (and/or awareness) which have an increased significance either from a safety or Sensitivity viewpoint. This policy was verbally communicated by the Regional Administrator, and reflected downwards through the two line Divisions to assure that when an inspector becomes aware of a significant problem, he immediately reports this to his supervision up to the' Division Director level, who when appropriate will notify the Regional Administrator. ROPG 0102 is b?ing reissued with region-wide applicability. ROPG 0102 is appended as Attachment 3.A. 3.5 ROPG 2201, " Disposition of Inspection Findings," ( Attachment 2. A) also addresses the issues of Safety significance, and regional attention and response for inspection findings. It provides the process for resolution of differing opinions on the significance or handling of inspection findings. Reconciliation of differences at the regional level is first defined, then if these are not successful, the R0PG directs the use of the DP0 route. R0PG 2201 specifically requires the use of the DP0 process rather than leaving of an item unreconciled in any party's mind, and permits the individual to go to the DP0 route at any time he feels the in-office process is not likely to reach an acceptable conclusion. 3.6 Followup and closeout of inspection findings is tracked by the Action Item Tracking system as specified in R0PG 1303, " Implementation cf Open Item Tracking System for Resident Sites and Regional Office." This ROPG provides g for tracking and closecut of Violations, Unresolved Items, Open Items, \\ Deviations. Deficiencies, etc. The Open Items list is utilized in preparing D ano approving inspection plans, with closeout priorities assigned based on the technical capability of tne inspector, resolution status by the licensee, and safety significance or impact. Unresolved Items typically resurface during the next inspection by the inspector who opened the item, since it is desirable to determine if the item is acceptable, or is a Violation or Deviation as soon as a sufficient basis exists. All Unresolved Items are resolved in subsequent inspection reports either as acceptable or enforcement action is initiated. R0PG 1303 is apoended as Attachment 3.B. R0PG 1320, " Control of Outstanding Action Items," (Attachment 3.C) was a precursor to RCPG 1330. 3.7 R0PG 1002, " Enforcement Conferences," has recently been revised to establish an enforcement panel to characterize enforcement actions to be taken following enforcement conferences. The intent is to provide a uniform review process to assure that the actions taken following enforcement conferences are uniform anc consistent with NRC policies. A copy of RDPG 1002 is appended as.0. f
INFORMATION REQUESTED _ l ( 4. Information that describes how Region IV intends that findings and items from inspections be " resolved" with regard to safety significance and 1 significance to the licensees performance. 1
RESPONSE
4.1 R0PG 2200, " Communications Regarding Inspections," requires that each inspector be debriefed by his Section Chief following inspections. The purpose of the debriefing is to surface Violations and Deficiencies identified and to l discuss the perceived need for an enforcement conference. The Section Chief is charged with the responsibility to bring significant issues to the attention of his Branch Chief on an expedited basis. The Section Chief is further required to review the draf ts of inspection reports. -Thir process is intended to assure surfacing of inspection findings having significance and to develop charac-terizations of licensee performance. Discussion preceding concerning reso-lution of inspection findings and tracking of inspection findings assures that tne inspection finoings are resolved, either by enforcement or by further inspection.
e 1 INFORMATION REQUESTED 5. The system or method used by Region IV to assure that appropriate Region IV staff members were aware and uncerstood the information in items 1-4. above. I
RESPONSE
5.1 In accordance with NRC Manual Chapter 1245, Inspector Qualific.ation, vd. I ROPG 0450, "The Qualification Journal and Inspector Certification " spe: #c l required training is provided to all inspectors. Supervisory personnel l normally would have taken similar training while inspectors, and may partiupate in training of inspectors, thereby sharpening their skills and refreshing themselves on the topics. This training program includes the Fundamentals of Inspection course discussed above. 5.2 The Regional Administrator personally conducts periodic meetings with two discreet groups of the regional technical staff: all technical staff, including inspectors and supervisors; and Branch Chiefs and Section Chiefs. Topics discussed are normally philosophical and specific direction based on observations by the Administrator during management of regional operation. These subjects are further discussed down line management, ano by Section Chiefs with their staffs. These meetings are held at least monthly, and frequently more often. 5.3 Resident Inspector Seminars are held semiannually. Attendance by the f regional inspection staff is encour' aged Topics discussed include a mix of i educational information and program directives. Periods are set aside for i supervisory interaction with their resident staffs. 5.4 The Regional Training Officer plans and coordinates a planned training program with the'nelp of representatives from each division. Topics incluce programmatic and administrative subjects. 5,5 The Branch Chief, Reactor Projects Branch, DRSP, holds conference call meetings with the Resident Inspectors on approximately a monthly frequency. 5,6 Supervisors hold periodic staff meetings, and meet individually with their staff memoers as necessary. 5.7 Appraisal sessions discuss not only performance, but areas where performance is inconsistent with policy. (
(_ ? 5.S RDPG 2205., " Supervisory Accompaniment of Staff," (Attachment 5.A) defines the required schedule for observation of inspector activities by supervisors. Not only are these accompaniments considered as a means for assessing l inspector performance and objectivity; but tney also are used as a training period by the supervisor. L 5.9 On occasion, memoranda to staff level groups are prepared by Section Chiefs and Branch Chiefs, to draw their attention to matters not specifically I covered by R0PG or IE and NRC Manual Chapters, or to draw attention to covered l matters. Examples of this type of memoranoum are provided in Attachments 1.C and 1.D. / r h E
1 INFORMATION REOUESTED i ~ -. 6. A copy of appropriate documents or relevant pages which address the above. -. matters.
RESPONSE
6.1 Listed below are R0PGs referenced above and other R0PGs which are peripheral to the issues identified. A copy of each listed R0PG not previously included in a discrete appendix is appended as Appendix 6. R0PG No. TITLE 0102 3.A Communications Regarding Items of Immediate Interest l 0211 Policy on Control of NRC Reports and Other Documents and 01 Referrals 0220' 1.B Meaning of Concurrence 0206 Completeness of Official Files 0209 Action Item Tracking System Procedures 0210 Policy.on the Distribution of Draft Inspection and Investigation Reports 0214 Action Request Tracking System ( ARTS) Procedures ? 0220 Meaning of Concurrence 0334 NRC Inspector Objectivity 0450 The Qualification Journal and Inspector Certification 0610 Outies and Responsibilities of the Project Inspector 0603 Communication of Generic Requirements to Reactor Licensees 0607 Operating Reactor Inspection Procedure Assignments 0608 NRC Use of INPO Evaluation Reports 0702 Power Reactor' Inspection Resource Review 1002 3.D Enforcement Conferences i 1005 Documentation of Similar or Records-Retrieval Violations 1006 Deviations f i
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R0PG No. __ITLE T ~ 1051 Procedures for Allegations and Investigations 1101 Confidentiality Procedures for Allegers 1102 Concurrence on Allegation Material 1303 3.8 Implementation of Open Item Tracking System for Resident Sites and Regional Office 1320' 3.C Control of Outstanding Action Items 1901 Documentation of Meetings 2200 4.A Communications Regarding Inspections 2201 2.A Disposition of Inspection Findings 2205 5.A Supervisory Accompaniment of Staff 2230 Reactor Inspection Reports and Associated Correspondence Issued to Reactor Licensees 2231 Standardized Report Letters for RIV Reactor Licensees RON No. TITLE ? 0610 Backfit Review Panel 1003 Expedited Processing of Escalated Enforcemen't Mail 1106 Formal Correspondence with Allegers 3200 Regional Office Policy Guide Table of Contents 3201 Regional Office Notice Table of Contents i I l 1 l
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\\ l ( '~ Attachments to Enclosure q 1 INDEX OF ATTACHMENTS l i l Attachment Contents of Attachment Number -1 l 1.A Resident Inspector Seminar Agenda and Regional Training Schedules 1.B R0PG 0220, Meaning of Concurrence 1.C Memorandum, R, E. Hall, Nov. 4, 1983 1.D Memorandum, Jerry Everett, Jan. 20, 1984 2.A ROPG 2201, Disposition of Inspection Findings 3.A R0PG 0102, Communications Regarding Items of Immediate Interest (. 3.B R0PG 1303, Implementation of Open Item Tracking System for Resident Sites and Regional Office 3.C ROPG 1320, Control of Outstanding Action items 3.0 R0PG 1002, Enforcement Conferences 4.A RDPG 2200, Communications Regarding Inspections 5.A ROPG 2205, Supervisory Accompaniment of Staff 6 Regional Office Policy Guides and Notices ) l l l l 1 ---__________________J
a ~ I si l J ATTACHF,ENT 1.A RON 04?S Regional Training Calendar (January 16,1986) RON0433(7) Regional Training Calendar (October 10,1986) l RON 0704 Agenda for Regional tieeting of Resident Inspectors (October 30-3'1, 1985) RON 0705 Attend $nce Requirements - October Resident Inspectors' ( lieeting i RON 0706 Agenda for' Regional Meeting of Resident Inspectors (April 23-24,1986) RON 0708 Agenda for Regional Meeting of Resident Inspectors -(October 28-30,1986) I
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NUCLEAR REGULATORY COMMISSION ,y'",., [, i.- c i REo ON IV ~ ) o '% ',,' Y l S 611 RYAN PLAZA DRIVE.$UtTE 1000 ,;/ ARLINGTOL TEXAS YE011 JAN 16 986 1 ' Regional Office Notice'No.i0428' 1 REGIONAL TRAINING CALENDAR i x A.
Purpose:
t To announce the development of a training program for the' Region IV - ) inspection staff. The purpose of the program is!to strengthen the staff's understanding'of various pertinent regulations and industry-standards that are the bases for various inspection requirements. j Attendance:at the training sessions will aid in inspector certification. I Attendance will be required of all region-based inspectors.'in the Division of Reactor Safety and Projects who have not completed their inspection certification training. Attendance will be' required of those inspectors .in the Division of Radiation Safety and Safeguards who have not completed their inspection certification training and who require the subject material in their training journal. .t-3 B. Discussion-Attached is the calendar for the training sessions. Instructors should -notify the Regional Training Assistant of any needed changes to the i schedule. All classes will be conducted in the 8th floor training room. It is intended that classes will be videotaped for later viewing by those inspectors who are excused by their supervisors for other duties. C. Action: Supervisors should ensure that applicable employees are aware of and 1 attend the required training unless 'other obligations preclude their j attendance. D. -
Contact:
Ann Poupard, ext. 122. E. Cancellation Date: This Notice is cancelled for record purposes on February 28, 1986. W f Dale A. Powers Regional Training Officer Distribution List D and E u__
i ) l l ~' i Recional 0ffice Notice No. 0428 JAN 161986 - cc: ) i R. D. Martin { P. S. Check T. Westerman j D. Smith, URF0 Training Committee Members: D. Powers A. Poupard .L. Ousley R. Doda D. Meyer W.'Seidle { J. Gagliardo D. Hunter R. Bangart Di' vision Secr'etaries ANO Resident Inspector Cooper Resident Inspector CPSES 1 Resident Inspector CPSES 2 Resident Inspector Fort Clahoun Resident Inspector Fort St. Vrain Resident Inspector River Bend Resident Inspector South Texas Resident Inspector Waterford-3 Resident Inspector Wolf Creek Resident inspector l ) i 4 ) I f l
I h JAN 16 EE ATTACHMENT l Date Time Subject Instructor 1/21 1:00 - 1:30 10 CFR 19 and 20 B. Murray 1/22 1:00 - 1:15 10 CFR 21 R. Hall 1/22 1:15 - 1:30 10 CFR 55 R. Cooley ~- 1/23 1:00 - 1:15 10 CFR 73 L. Yandell ~ 1/23 1:15 - 1:30 ANSI N18.1 J. Jaudon 1/24 1:00 - 1:30 10 CFR 50 J. Gagliardo 2/18 1:00 - 1:30 Notice of Violations E. Johnson _2/19 1:00 - 1:30 ANSI N18.7 and RG 1.33 D. Hunter ) 2/20 1:00 - 1:15 FSAR W. Siedle j 2/20 1:15 - 1:30 RG 1.28 and NQ1 L. Constable 2/21 1:00 - 1:15 IEEE Standards R. Ireland 2/21 1:15 - 1:30 ASME Section XI D. Hunnicutt o. m .k j e 2 1
n. as a.-usa ...a....;... )* s ** ""%'s, UNITED STATES $~e ', /; NUCLEAR REGULATORY COMMISSION ~ a-c l MEGION IV .9 / 611 RYAN PLAZA DRIVE, SUITE 1000 i { ARLINGTON, TEXAS 74011 OCT 10 806 l Regional Office Notice No. 0433(7) REGIONAL TRAINING CALENDAR A. Pu rpose : To disseminate the Regional Training Calendar. i B. Discussion: Attached is the calendar for all scheduled Regional training sessions. All revisions to the training calendar will be duly indicated on the 1 posted copies outside the 10th floor training room and the 8th floor conference room. C. Action: Supervisors should ensure that employees are aware of and attend applicable training unless other obligations preclude their attendance. {, 3 = Instructors or training comunittee members should notify the Regional Training Assistant of any needed changes to the schedule, if videotaping is desired, or if class evaluations are to be requested. that instructors or training cousaittee members who may be presentIt is requested circulate attendance sheets at each session. Return attendance sheets and evaluation forms to A. Poupard for filing. D.
Contact:
Ann Poupard, ext. 122. E. Cancellation Date: This Notice remains in effect until superseded. Dale A. Powers 4 Regional Training Officer Distribution List C cc: TTC I 1 l l l \\
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M**"'6'., UNITED STATES [, . NUCIEAR NEGULATORY COMMISSION 4 b REGION IV I -{ , d,f 611 RYAN PLAZA DRIVE. SulTE 1000 ARLINGTON. TEXAS 76011 OCT O 4 IMS i'l Recional Office Notice No. 0704 1 AGENDA-FOR REGIONAL MEETING OF RESIDENT INSPECTORS A. Purpose To publish the agenda for the October 30-31, 1985, meeting. B. Discussion The enclosure was developed through contact with the resident inspectors, regional staff and headquarters personnel. Regional attendance is encouraged. 'C. Action Those listed _in the Enclosure should be prepared for discussions and/or presentations as scheduled. ( D. Contact i Suggestions.or comments should be directed to Bill Seidle, Chief, Technical Support Staff, Division of Reactor Safety and Projects, FTS 728-8148. E. Cancellation Date This notice is cancelled November 1,1985. p / '\\' )' g Richard P. Denise, Di tor Division of Reactor Safety and Projects Enclosures as stated Distribution List C 1 .( k
t ' l ( l AGENDA FOR THE OCTOBER 1985 REGIONAL MEETING 0F r RESIDENT AND SENIOR RESIDENT INSPECTORS (Meeting to be held in'the 8th Floor Conference Room) Wednesday - October-30 Time Subject Discussion Leaders 8:00 - 8:15 Welcoming.of Resident Inspectors Dick Denise 8:15 - 9:15 General Discussion - Current Issues Bob Martin 9:;5 -'9:30 Processing Allegations Received by Mark Emerson Resident Inspectors i 9:30 - 9:45 Break (- 9:45 - 10: 45 . Current NRC Issues Vic Stello (EDO)' .i 'g 10:45 - 11:15 Proper Methodology for Acquiring Don Driskill (01) . True Copies of Records 11:15 - 12:00 Discuss Current DRSP Activities / Issues Dick Denise 12:00 -'1:00 Lunch' 1:00 - 1:30 Incident Investigation Program Jack Heltemes, i (AE00) 1:30 - 2:30 Davis-Besse Feedwater Incident Ernie Rossi (EAB) 2:30 - 2:45 Break 2:45 - 4:00 Continue Davis-Besse Feedwater Ernie Rossi (EAB) Incident Discussions 4:00 - 4:30 Comparison of Davis-Besse and Bill Johnson ANO-Unit 1, As Relates to Feedwater Incident i
I
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Thursday-October 31 ( Time Subject Discussion . 8:00 - 9:45-Resident Inspectors' Involvement James Kelly With Physical Plant Security -9:45 - 10iOO. Break J 10:00 - 12:00 Fitness for Duty David Lons ) i (Consul tar,t ) . i 12:00 - 1:00 Lunch j 1:00 - 2:00 . Fermi Premature Criticality Incident Nick Chrissotimos (RIII)- l 2:00 - 2:30 Role of FEMA. J. B. Baird 2:30'- 2:45 Break 2:45 - 3:45 Resident Inspectors Role in Cheryl Sakenas Transportation Accidents (IRB) 3:45 - 4:30 Core Degradation Considerations Cheryl Sakenas and Protective Action Decision (IRB) I Making i l
ff""%. UNITED STATES c... NUCLEAR REGULATORY COMMISSION 4 .i )ei ; $ $;{ " / f' REoloN IV ,g 3 811 RYAN P(AZA DRIVE. SufTE 1000 ~ _g o,,,,, ARUNGToN, TEXAS 79011 e OCT 101985 Regional Office Notice No. 0705 ATTENDANCE REQUIREMENTS - OCTOBER RESIDENT INSPECTORS' MEETING A.
Purpose:
To identify specific discussion sessions scheduled for presentation l during 'the forthcoming Resident Inspectors' meeting that will be required attendance for the regional technical. staff. (Ref: Regional Office Notice 0704, dated October 4, 1985). B.. Discussion: Victor Stello Jr., Deputy Executive Director for Operations,. will discuss j i Current NRC Issues beginning at 9:45AM on October 30.. Jack Heltenes, Director, AEOD, and Ernie Rossi, Chief Events Analysis Branch, will discuss the Incident Investigation Program and the Davis-8 esse Feedwater Incident beginning at 1:00PM on October 30. David Long.. Consultant, will discuss Fitness for Duty (drug and alcohol abuse) beginning!at 10 00AM on' October 31. Nick chrissotinos, Chief, Reactor Profsictif 8 ranch.;NoO 2, (- RIII, will discuss the Fenni Premature Criticality-Incidentibegt,nning'at-1:00PM on October 31. These discussion sessionstw11E, provide?fspostantJnfor-8 mation to all technical staff employees, and should?betkipfuEtniarrying~~ 'i out assigned tasks. i..F.. Js? ~ %.$.s#.wf.; A ' ':w?.**.$ ^ 3 !"$h.E.$ ~,,l Yd .r [,_ l:f_fyh(N.. All technical staff employees scheduled to be in".the officFare.f' required to attend tha discussion sessions identified in, parapaph:8,s.abovei Employees scheduled to be in travel status or.on annual: leave on October 30 and/or 31, should not change their plansrinidrBer to-attend these sessions. ,. yW.. c;.j, r (p., ,,,c. c... - D.
Contact:
- D 3' ')..: W. C. Seidle (Ext.148). E. Cancellation Date: -v \\ ) This notice is cancelled on November 1, 1985 / A ^ obert D. Martin ~ ~ o 4, Regional Administrator l Distribution List B l
y ) /*"'%, UNITED STATES 7w, NUCLEAR REGULATORY COMMISSION f' ' 'k" 5 REGION IV e,h . [8.f 611 RYAN PLAZA DRfvE. SutTE 1000 ARUNGTON, TEXAS 78011 ~' M 311985 i i Regional Office Notice No. 0706 i AGENDA FOR REGIONAL MEETING OF RESIDENT INSPECTORS A.
Purpose:
To publish the agenda for the April 23-24, 1986, meeting. B. Discussion: The enclosure was developed through contact with the resident inspectors, regional staff, headquarters personnel and the Federal Aviation Administration. Regional attendance is encouraged. C. . Action: Those listed in the Enclosure thould be prepared for discussions and/or presentations as scheduled. 3 D.
Contact:
J Suggestions or comments should be directed to 8111 Seidle, Chief. Technical Support Staff Division of Reactor Safety and Projects. FTS 728-8148. E. Cancellation Date: This notice is cancelled April 25, 1986. Eric H. Johnson, Director Division of Reactor Safety and Projects Enclosures as stated Distribution List C o
FAR 311985 ( J. Sniezek, DEDROGR ~ J. Taylor, IE L. Robinson, OA E. Shomaker, ELD R. Baer, IE J. Fanning, OA I P. Kaplan, OCM J. Axelrad, IE E. Butcher, NRR T. Dunning, NRR P. McKee, IE R. Knight, FAA D. Eisenhut, NRR -- T. Murley, RA, RI l J. Grace, RA, RII J. Keppler, RA, RIII i J. Martin, RA, RV e= i '4 l f i
L,- Enclosure AGENDA FOR THE APRIL 1986 REGIONAL MEETING OF RESIDENT AND SENIOR RESIDENT INSPECTORS Wednesday - April 23 Time Subject Discussion Leader 8:00 8:15 Welcoming of Resident Inspectors Eric Johnson 8:15 9:00 General Discussion - Current Issues Paul Check 9:00 - 10:00 FOIA Lyn Robinson (FIPB) Ed Shomaker (ELD) t-10:00 - 10:15 Break 10:15 --10:45 Sheared RC Pump Shaft Event at Dorwin Hunter ) Crystal River - Operational Aspect 10:45 - 12:00 Overview of Engineering and Generic Bob Baer (EGCB) 1 Concerns; Discuss Current Technical Issues 12:00 1:00 Lunch 1:00 2:45 Drug and Alcohol Abuse RedsFanninf0CM) (PSS). Pat Kaplan 2:45 3:00 Break J 3:00 4:30 Licensee's Corrective Action Systems Jim Gagliardo
/ ~ 1" ~ Thursday - April 24 Time Subject Discussion Leader l 8:00 9:30 General Enforcement Policy Jane Axelrad (D/ES) 9:30 9:45 Break 9:45 - 10:30 Discuss Current DRSP Activities / Eric Johnson Issues i 10:30 - 12:00 General Discussion on FAA Roger Knight (FAA) Inspection and Enforcement Program '1 12:00 1:00 Lunch i 1:00 2:30 NRC Technical Specifications Ed Butcher (HFTS) Improvement Program TomDunning(HFTS) 2:30 2:45 Break 2:45 3:45 Inspection Program Development Phil McKee (ORPG) Topics Including TI for Inspection E0Ps 3:45 4:30 Round Table Discussion Paul Check Eric Johnson Dick Bangart Chip Foster
I ~ .f" UNITED STATES [ y ',,, ' '; NUCLEAR REGULATORY COMMISSION It, f ~ REGloNIV" f i,, g, e $11 RYAN PLAZA oRIVE SutTE 1000 ARLINGTON, TEXAS 76011 1 OCT 4 6 NE Regional Office Notice No. 0708 gn. AGENDA FOR REGIDNAL MEETING OF RESIDENT INSPECTORS A.
Purpose:
To publish the agenda for the October 28-30, 1986, meeting which will be held in the Region IV Office - eighth floor conferenca room,. n3 B. Discussion: The enclosure was developed through contact with the resident inspectors, regional staff, headquarters personnel and the National Transportation Safety Board. Regional attendance is encouraged. { l 1 C. Action: Those listed in the Enclosure should be prepared for discussions and/or presentations as scheduled. I D.-
Contact:
+ Suggestions or connents should be directed to Bill Seidle, Chief, Technical Support Staff. Division of Peactor Safety and Projects. FTS 728-8148. E. Cancellation Date: This notice remains in effect until superseded. bb h { Eric H. Johnson, Director Division of Reactor Safety and Projects Enclosure As stated Distribution List C l l l
OCT 0 u B86 n. u ~ [ Enclosure AGENDA FOR THE DCTMER 1986 REGIONAL MEETING OF RESIDENT AND SENIOR RESIDENT INSPECTORS Tuesday - October 28 ~ Time Subjeqt Discussion Leader. 1 s 8:00 - 8:15. Welcoming of Resident Inspectdrs Eric Johnson i 8:15 - 9:00 General Discussion - Current Issues Bob Martin ~ MiAp SHrecs' Thr._[Sp S 9:00 - 10:00 Chernobyl Accident (NRR) 10:00 - 10:15 Break ~ 10:15 - 10:45 Briefing on Recent ANS Executive Paul Check Workshops on Industry /NRC Inspection Larry Yandell ~ Interface (' 10:45 - 11:00 Physical Plant Security Items Larry Yandell i 11:00 - 11:30 Perfonnance Indicators > Ray Hall.. 11:30 - 12:30 Lunch e 12:30 - 1:30 Phase I Findings of NRCTMaintenance Bernie Grenier & Surveillance Prograi Plan (NRR) 2:00 Survey of UtiNty Mtnagement Blen Madsen 1:30 ~ 2:00 2:30 Use of PRISIM at M0 Bill Johnson 2:45 Break E 2:30 2:45 4:00 TMI-2 Cleanup Update Bill Travers (NRR) H 4:00 5:00 Current ORSP Issues
- Eric Johnson l
s i (
--.._.y OCT 0 61986 2 Wecncsday - October 29 Time Subject Discussion Lead _er 8:00 10:00 Implementing Backfit Policies TomCox(EDO) and Procedures 10:00 10:15 Break ^ 10:15 11:15 Current OIE Issues Jim Taylor (OIE) 11:15 11:45 Emergency Operating Procedure Rick Bennett (T12515-79) 11:45 - 12:45 Lunch 12:45 2:15 Technical Round Table Discussion Jim Gagliardo (including report writing, inspector utilization, new approach to SALP, jumper control) ~ 2:15 2:30 Break g 2:30 3:30 General Discussior. on National Warren Wandel Transportation Safety Board (NTSB) -9 investigations 3:30 4:30 Security Briefing Connie Dollar o ,7 ru >>rks; e,
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sie rsp;;2,_ f S c) i u 4 l i "y 1 ,c I .w
OCT e 6 896 Thursday - October 30 Time Subject Discussion Leader 9:00 New Retirement Plan Chip Foster 8:00 Karen League 9:45 New Travel Regulations Dee Meyer 9:00 9:45 10:00 Break 10:00 - 12:00 PRA Application in Inspection Bernie killman Programs (RI) 12:00 - 1:00 Lunch 4 irk MtEMO'S (d(-C) .n - ix styggc y F.w4prA. -hee - 3 00 View Chernobyl Tapes a.sc ww (Optional) .P i I l I
OCT 0 6 lggs -4. J. Sniezek, ED0 -l J. Taylor. IE T. Speis, NRR B. Grenier, NRR W. Travers, NRR j T. Cox, EDO W. Wandel, NTSB B. Hillman, RI R. Vollmer, NRR T. Murley, RA, RI J. Grace RA, RII J. Keppler, PA, RIII J. Martin, RA, RV 8 es*
i ef 4, UNITED STATES . p ',,, 4 NUCLEAR REGULATORY COMMISSION . j REQloN IV ik,,,'# G11 RYAN PLAZA DRIVE SunE 1000 j ARUNGTON, TEXAS 75011 ~ l GCT 4 8 506 Regional Office Notice No. 0709 ATTENDANCE REQUIREMENTS - OCTOBER RESIDENT INSPECTORS' MEETING 'l A.
Purpose:
1 To identify specific discussion sessions scheduled for presentation during the forthcoming Resident Inspectors' meeting that will be required attendance for the regional technical staff (Ref: Regional 0ffice i Notice, No. 0708, dated October 3,1966). -{ B. Discussion: 1. Tom Cox, Senior Program Manager, Regional Operations and Generic Requirements Staff. EDO, will discuss Implementation of Backfit Policies and Procedures beginning at 8:00 AM on October 29. Jim Taylor, Director. Office of Inspection and Enforcement, will discuss Current 01E Issues beginning at 10:15 AM on October 29. Connie Dollar, Chief. Administrative Management Branch, will conduct the annual Security Briefinq beginning at 3:30 PM on October 29. These discussion sessions w'11 provide important infomation to all technical staff employees and should be helpful in carrying out assigned tasks. 2. Themis Speis Diriector, Division of Safety Review and Oversight Office of NRR, will discuss the Chernobyl Accident beginning at 9:00 AM on October 28. Bill Travers, D1metor TMI-2 Cleanup Project Directorate, NRR will discuss the current status of the j TMI-2 Cleanup beginning at 2:45 PM, October 28. Warren Wandel Air safety Investigator, National Transportation Safety Board, will conduct a general discussion on NTSB Investigation beginning at 2:30 PM on October 29. These should be very interesting and l informative discussions. l C. Action: i All technical staff employees scheduled to be in the office are required to attend the discussion sessions identified in paragraph 8.1., above. Employees scheduled to be in travel status or on annual leave October 28 and/or 29 should not change their plans in order to attend the sessions. All regional staff employees are strongly urged tc sttend the discussion session identified in paragraph 8.2., above. ] \\ A
I OCT 0 8 586-l Regjonal Office Notice No. 0709 All technical DRSP personnel scheduled to be in the office are required to attend all of the technically oriented sessions except the session on the viewing of the Chernobyl Tapes where attendance is optional. D.
Contact:
Bill Seidle (Ext. 148). E. Cancellation Date: This notice remains in effect until supe seded. Y Robert D. Martin Regional Administrator Distribution List C e m i e e l
l l ATTACHMENT 1.8 R0PG 0220 Meaning of Concurrence (Rev. 1) ROFG 0220 tieaning of Concurrence (Rev. 0) r l
g *h [.. 15 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV - (( 611 RYAN PLAZA DRIVE, SUITE 1000 ,N, ARLINGTON. TEXAS 76011 DEC 2 91986 Recional Office Policy Guide No. 0220, Revision 1 MEANING OF CONCURRENCE A. Pu rpose i To establish a region-wide definition of what concurrence by a Region IV I employee means on a concurrence sheet of a report, memorandum, or other documents. ] B. Discussion: This guide was necessitated by the apparent confusion of one or more employees as to what was the meaning of their individual concurrences in various documents. C. Action: When a Region IV employee initials or signs his or her name on a j concurrence sheet of a report, memorandum, or other document, the employee is formally stating that he or she is in agreement with the report, memorandum, or other document in those creas for which the H i employee has knowledge, expertise, or responsibility. No employee should concur in any document if he or she does not agree with those aspects of the document for which he or she has knowledge, expertise, or responsibility. Disagreement as to a document should be worked out with supervisors or other appropriate parties, depending on the situation, in accordance with applicable policy. In some cases a nonconcurrence may i be appropriate. In such a case, the nonconcurring employee should note the nonconcurrence on the concurrence sheet and document the reason for the nonconcurrence in writing to his or her supervisor. A copy of such documentation should be sent to the region's central file room for inclusion in the applicable docket file along with the reference correspondence. l D.
Contact:
Suggestions or comments should be directed to the Regional Counsel, Ext. 271. E. Effective Date: This Policy Guide is in effect when issued W/ sd k obert D. Martin Regional Administrator Distribution List C
I p*** ""% UNITED STATES - ev NUCLEAR REGULATORY COMMISSION % g j/ l REGION IV 7I i -E S, g
- I 611 RYAN Pt.AZA DRfVE. SUfTE 10o0 ARUNGTON. TEXAS 7to11 l
APR 2119g5 Regional Office Policy Guide No. 0220, Revision 0 MEANING OF CONCURRENCE l A.
Purpose:
To establish a region-wide definition of what concurrence by a Region IV employee means on a concurrence sheet of a report, memorandum, or other documents. B. Discussion: This guide was necessitated by the apparent confusion of one or more employees as to what was the meaning of their individual concurrences in various documents. C. Action: When a Region IV employee initials or signs his or her name on a concurrence sheet of a report, memorandum, or other document, the employee is formally stating that he or she is in agreement with the '( report, memorandum, or other document in those areas for which the employee has knowledge, expertise, or responsibility. No employee should concur in any document if he or she does not agree with those aspects of the document for which he or she has knowledge, expertise. or responsibility. Disagreement as to a meument should be worked out with supervisors or other appropriate parties, depending on the situation, in accordance with applicable policy. In some cases a' nonconcurrence may be appropriate. D.
Contact:
Suggestions or comments should be directed to the Regional Counsel, Ext. 271. E. Effective Date: This Policy Guide is in effect when issu { ~ / J l Robert D. Martin l Regional Administrator Distribution List C I
. - ~..... ~. ~......, -... ~ ~,...... ~.. .. ~... - . ~ t ' 1 l l \\ 1 ATTAC W ENT 1.C I I I Memorandum, R. E. 'riall, " Inspection Report Concurrence Procedure *" dated hovember 4,1983 4 t i l o l l l l
f; UNITED STATES NUCLEAR REGULATORY. COMMISSION i REGION IV ( '8
- l. /'[
611 RYAN PLAZA DRIVE, SUITE,1000 h, ARLINGTON. TEX AS 76011 04 NOV 1983 MEMORANDUM FOR: Technical Program Branch Staff FROM: R. E. Hall, Chief, Technical Program Branch
SUBJECT:
INSPECTION REPORT CONCURRENCE PROCEDURE Effective with creation of the Data Management Unit (DMU), all inspection reports will be typed in the DMU using the IBM 5520 system. To effectively use the DMU, it will be necessary to formalize the procedures to be followed for comment, review, and concurrence. The appended control sheet (traveler) will be used for all reports to guide the report and to provide a record of the document cycle for reporting purposes. Specific steps to be followed are: 1. Inspectors prepare draft of report and open item tracking system input form (when applicable), and place in folder with inspection report route sheet (filling in appropriate boxes) stapled on outside. Tne draft and supporting information should be logged in and given to the Branch e Secretary within 10 working days of the end of the inspection. Review of handwritten draft by Section Chief will be for general format and content as appropriate. 2. The Branch Secretary will update the 5520 tracking system and TPB log. l She will then forward the report to the DMU for draft typing, 3. Upon return of the draft from DMU, the Branch Secretary will review the report for format and completeness. The report will then be returned to the principal author. 4 The author will review the draft for accuracy, format, content, and will assure that it is dramatically correct. All changes to the draft should i be in red (felt marker, pen, or pencil). 5. Tne draft will then be reviewed by the Section Chief and Branch Chief in turn. Any changes to the report (other then correction of obvious typographical errors) will be reviewed with the author to assure that report intent is not altered. 6. The draf t will then be returned to the Branch Secretary for resubmittal to the DMU for final typing. l
= _ _ _ _ _ _. - _ _ _ _ _ _ _ 2 7. Upon return-of the final report f rom DMU, the Branch Secretary will { proofread the report for compliance with NRC correspondence guidance, and. { assure that all corrections have been properly incorporated. The final ) will then be returned to the principal author. J 8. Afte* final proofreading by the author, he will sign the report, obtain the signatures of other involved inspectors, concur on the transmittal letter, and forward it to the Section Chief. 9. The Section Chief and Branch Chief in turn will review the final report. The Section Chief will approve the report and concur on the transmittal letter, and the Branch Chief will sign the transmittal letter. 10. If changes-to the final report are necessary, the Branch Secretary will either make the final changes or return the report to DMU based on the extent of the corrections. After return of the corrected final report, reconcurrences will be obtained only if necessary, and the report will be forwarded to the office of the Division Director for his concurrence.
- 11. Af ter report issuance, the control sheet will be returned to the Branch Chief for review and then to the Branch Secretary for retention.
For inspection reports not entailing escalated enforcement or principal investigations, it will be the objective of the Branch to have all reports issued within 25 calender days (normally 20 working days) of the end of the e inspection. For any report not issued within this time, the control sheet will be reviewed by the principal author and the cause for the late report justified in a note to be appended to the control sheet when filed. The most visible measure of the professionalism and performance of this Branch is our inspection report system. Care taken on the part of each report author to assure preparation and issuance of a quality report in a timely manner will reflect favorably on our Branch. If all necessary changes are made on the draft, approval and issuance of the final report should be 3xpedited, r . J' R. E. Hall, Chief Technical Program Branch
INSPECTIOT4 REDORT ROUTE SHEET 5520 Controi l,o, LICEliSEE/ VENDOR: DCCKET NO.. REP 0RT NO.: INSPECTOR: I - INSPECTION DATE(5) PRIORITY Branch Chief REPORT DUE DATE i INITIAL /DATE i HAIS'RITTEI4 DRAFT COMPLETED DATE REPORT MAILED: REVIEW BY SECTION CHIEF ^ RETURN FOR REWORK (i:.spector) RESPONSE DUE - 30 DAYS'- REWORK C0ftPLETE CLOSE0UT DATE: DRAFT REC'D - DMU j ,,0 RAFT TYPIf4G COMPLETE DRAFT REVIEW BY SEC'Y/ INSPECTOR COMMENTS: DRAFT REVIEW BY SECTION CHIEF ? ORAFT REVIEW BY BRANCH CHIEF RETURN FOR REWOF,K (inspector) REWORK "0MPLETE FINAL REC' D - DMU FINAL TYPING COMPLETE FINAL REVIEW BR. SEC'Y/DIV. SEC'Y l 1 FINAL REVIEW BY INSPECTOR FINAL REVIEW BY SECTION CHIEF l RETURN FOR CORRECTIONS - DMU l CORRECTIONS COMPLETE - DMU -CORRECTION REVIEW - INSP/ SECT. CH. FINAL REVIEW BY BRANCH CHIEF - 0: VISION DIRECTOR REVRW ENFORCEfiENT REVIEW l
F 4 ATTACHMENT 1.D E Memorar.dum, Jerry Everett, " Processing of Reports, Letters, NOVs (Revision 1)" dated January 20, 1984 E 1 O i
[ N'., UNll!O STATES [< NUCLEAR REGULATORY COMMISSION h,p I C f .n REGloN IV ,[ 1, # 611 RYAN Pt AZA oRIVE, SUITE 1000 ,2 ARLINGTON. TEX AS 76011 2 0 JAN 1984 MEMORAfiDUM FOR: Materials Radiation Protection Section Staff FROM: Jerry Everett, Chief, MRPS
SUBJECT:
PROCESSING OF REPORTS, LETTERS, NOVS (REVISION 1) In the interest of uniformity and efficiency, please follow the following procedures in processing your inspection reports and related correspondence: 1, 591 Inspections The inspector will complete the 766 form recording the current and a. next inspection dates as well as the date the 591 was issued in the TTeTd. The inspector will forward a copy of the 766 and one copy of the 591 form to the computer section and the original of the 766 and original of the 591 to the branch secretary. The inspector will make a copy for the docket file and himself. The secretary will make the required distribution with these copies. For 591 fonns brought back to the office, the inspector will complete all entries except the date of issue. Copies of the 591 and 766 will be given to the secretary who will supply the date of issue then forward to the computer section, b. The inspector will attach one copy of the 766, 591, and the draft inspection report to the docket file and forward to the Section Chief, The Section Chief will review the package and return to the c. secretary. d. The secretary will give the file to the docket room. 2. Inspections Requiring Transmittal Letters and NOVs The inspector will complete the letter, NOV, or report (if a. required), and the 766 and forward to the branch secretary, b. The secretary will arrange typing and return the documents to the inspector for review. The inspector will review the documents, ensuring their correctness, c. then forward them thru the concurrence chain, i
~ 2 d. Upon approval, the secretary will compile the documents, sending I the inspector's copy plus the docket file copy to the inspector (for attached inspection reports, distribution outside must await ') 2.79 review). The secretary will complete the 766 form, recording the date the. e. letter was sent. A copy of the 766 and the letter /NOV is forwarded to the computer section by the secretary, f. The docket file will be retained by the inspector until final action has been taken (i.e. ccpy of final thank-you letter). At that time, ~ the inspector will forwed the complete package, including the draft or formal inspection report, 766, and docket file to the Section Chief. g. The Section Chief will review the package and return to the secretary. h. The' secretary will give the file to the docket room. 9 J ry verett, Chief MRPS cc: R. Hall R. Bangart J. Perry i l f
( ~ ATTACHMENT 2.A x ROPG 2201 Disposition of Inspection Findings (Rev. 0) r e J
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UNITED STATES -+ NUCLEAR REGULATORY COMMISSION k REGION IV 611 RYAN PLAZA DRIVE. SUITE 1000 ARUNCTON. TEX A5 76011 Regional Office Policy Guide No. 2201, Revision 0 l DISPOSITION OF INSPECTION FINDINGS A.
Purpose:
To provide the staff with an understanding of the definite expectations of regional management concerning the identification, classification, and documentation of-inspection findings, with particular emphasis on the mechanism for resolution of inspection findings involving differing professional opinions. B. Discussion: I The function of NRC inspectors during inspections is to verify compliance of a licensee with requirements incumbent upon him, and commitments he hds made to the NRC, Inspector findings are normally discussed with the licensee during inspection exit meetings, during which the findings are normally t ' categorized as apparent violations, deviations, unresolved items, followup items or improvement items. The licensee should be cautioned by a the inspectors that the findings as he portrays them may be revised after ~ consideration by regional supervision and management. In no case should the licensee be advised of the fact that the severity level of a violation has been determined or that escalated enforcement is being planned based on the findings from a specific inspection. After review of the inspection-findings by regional supervision, determinations of severity level, and the need for an enforcement conference will be established. Subsequent correspondence with the licensee will be processed from the region, and if an enforcement conference is held, severity level detenninations will be finalized after the enforcement conference. Inspectors also identify weaknesses in licensee programs or practices which are not at variance with requirements and commitments, but which, in the opinion of the inspector should be corrected. In some cases, inspector findings may require revision of NRC requirements or interpretation of the applicable requirements or consnitments. In cases of this nature and in cases needing program office guidance, the matter shall be identified by the inspector to his supervisor. If requested by the supervisor, a memorandum shall be prepared by the inspector to his supervisor, identifying the problem and proposing the appropriate resolution or posing the question on which guidance is sought. After discussion, the i inspector's Branch Chief may endorse the inspector's memorandum, and transmit it to his counterpart in the appropriate program office for assistance in resolution, t 1
Pegional Office lolicy Guide No. F 01._ hevision 0 -The process of review of inspection findings may lead to issuonce of an NRC inspection report that differs in some substantial way from the inspector's original judgement. Supervision and management are responsible for evaluating the significance of an _ inspector's findings and for assuring that correspondence relating to these findings is consistent with NRC pclicy and guidance. Whenever any inspector believes that his' positions are not being adequately considered as part of the normal discussion of work matters, and his concern cannot be resolved through discussion with co-workers and immediate supervision, and if the: inspector believes ~ additional review of the matter is :necessary, regional management considers the individual to be under a positive professional obligation to utilize the appeal process of Manual Chapter 4125, " Differing Professional Opinions," to assure consideration of his concerns by appropriate management. Similarly, supervisors' and management have the positive. responsibility and obligation to process the individual's concerns in accordance with the procedures and schedules contained within Manual Chapter.4125. Failure to utilize and follow the provisions of Manual Chapter 4125 to assure resolution of identified concerns should be considered not only as nonprofessional, but also may be an indicator of unacceptable performance. C. Action: G The following procedures are designed to assure proper consideration, documentation and resolution of inspector findings. The enclosure depicts the. logic flow for resolution of findings. 1. Supervisors should discuss inspection findings with inspectors during .or imediately following the inspection and solicit the views of other NRC staff on the matters unoer discussion. Differing viewpoints shall be discussed with the involved inspector and resolved at that stage if possible. If the issue can be resolved, the inspection report draft will be edited to reflect the final detennination and issued. Satisfactory resolution includes the case where the difference is recognized to be a -matter of judgement and the inspector accepts the judgement of the supervisor. Should there remain cases where a mutually acceptable understanding cannot be agreed to by all parties, or one party feels that his viewpoints have not been adequately considered, the issue shall be referred to the next higher level of supervision for resolution. The issue may also be discussed with regional management including the Regional Administrator if the. concerned incividual feels that further consideration may resolve the issue before issuance of the inspection report. The inspection findings should not be altered or deleted af ter the involved inspector has signed the report cover sheet without discussion with, and concurrence of, the involved inspector. If
I ~ ggiorjai O Uice Policy Luice f.o. 2201 - r,evision 0 agreement Cannot be obtdined, the supervisor shall direct the involved inspector to remove the item from the inspection report for separate consideration. The inspection report shall then be issued without the questioned item. 2. Af ter issuance of a report, should there remain concerns on the part of any person involved in thc i spection report preparation process n regaroing the technical adequacy or accuracy of the issued inspection report, or should any party feel that his viewpoints have not been adequately considered, the concerned individual may document his . concerns for full and complete consideration in accordance with NRC l Manual Chapter 4125, " Differing Professional Opinions." For each item, the concern of the inspector should be identified along with the appropriate regulatory references. Each item should contain sufficient infonnation to permit full review and consideration without referring to other documentation. The documentation shall be sufficiently complete to accurately portray the technical aspects of the concern and to explain significance to safety. The handling of the item, and the outstanding concern shall be described if appropriate. i 3. The inspector's supervisor and next higher level of supervision shall review the submitted item of concern, its basis for disposition, discuss the matter with the involved personnel, and prepare a memorandum acknowledging receipt of the concern as required by NRC Manual Chapter 4125. The response shall be discussed with the concerned individual, and a copy given to him for his records. A copy of the initial concern and the response shall also be placed in the regional docket file if it pertains to a docketed facility. If the matter concerns an issue under review by a hearing board, the NRR Project Manager or appropriate program office contact shall be informed by the Branch or Section Chief. 4 If the responses prepared by supervision are not sufficient to allay the concern of the individual following the discussion, the matter shall be processed in accordance with NRC Manual Chapter 4125 for consideration by appropriate regional and headquarters management. D.
Contact:
Suggestions or connents should be directed to the Deputy Regional Administrator (ext. 222). (
i i ~ ~ l ~ ) kegier.al Office Pclicy Guide f;o. 2201 r ~4 - ) Revisluo 0 l J i E. Effective Date: This Policy Guide is in effect when issued. obert D. Martin i Regional Administrator Logic flow chart Distribution List C = i l' 1 1 1 m
' 0GIC FLOW CHAT'T Enclosure to R0PG 2201 Inspector Observation or Finding u Significant Findings J Reviewed by Telephone with Section Chief Inspection Findings i Discussed with Licensee at Exit I f-Discuss Findings with Section Chief and Draft Report Agrhement on Findings? 1 2 I inspector Documents Write Final Report Finalize Differing Viewpoint without Item Inspection Report a v Branch Chief Reviews !ssue Report o and Documents his Issue Report i
Response
j v o o Agree? Prepare and Process Dispose of Drafts i DP0 per NRC MC 4125 and non-agency Records per 4 R0PG 0206 s I v 4 Requests meeting i with Div. Dir. and/or Reg. Acm? 49 2 7 l Accepts Regional Decision? 5/30/86 ) 5 { 1 2 i -______-______O
i l 4 1 i b i i l J ROPG 2201 (0) DISPOSITION OF INSPECTION FINDINGS PURPOSE 1. ~ DEFINITE EXPECTATIONS OF REGIONAL MANAGEMENT 2. MECHANISM FOR RESOLUTION OF CONTROVERSIAL FINDIf4GS I 3. AVAILABILITY OF DPO ROUTE i t
k- ~ r-1 NRC INSPECTOR FUNCTION ~ 'NRC INSPECTORS VERIFY COMPLIANCE OF A LICENSEE WITH REQUIREMENTS' INCUMBENT UPON HIM, AND COMMITMENTS HE HAS~MADE TO THE NHC. .7 l i
I' 2-1 -INSPECTOR FINDINGS 1. DISCUSSED WITH SUPERVISION IF SIGNIFICANT OR UNUSUAL 2. DISCUSSED WITH LICENSEE IN EXIT ~ 2.1 PORTRAYED AS APPARENT VIOLATIONS, ETC.
- 2. 2 SEVERITY LEVELS NOT DISCUSSED.
( 2.3 SUBJECT TO CHANGE BASED ON SUPERVISORY REVIEW. 9 3. SEVERITY LEVELS ON EXCALATED ENFORCEMENT DETERMINED AFTER ENFORCEMENT CONFERENCE. 4. FINDINGS WITHOUT FIRM REGULATORY BASIS 4.1 SUGGESTIONS FOR IMPROVEMENT 4.2 REQUEST TO OIE FOR GUIDANCE 4.3 RECOMMENDATION FOR REQUIREMENT CHANGE l
] 1 ~ ~ W9 3 I DOCUMENTATION OF FINDINGS 1. INSPECTION REPORT WITH ENFORCEMENT 2. SUPERVISORY REVIEW OF REPORT 3. ' CHANGES TO. DOCUMENTATION OF FINDINGS 4 DIFFERING PROFESSIONAL OPINION l' 1 I
t ATTACHMENT 3.A R0PG 0102 Ccmunications Re9arding items of Immediate Interent (Rev. 1) 8a l l l 1 l l
l-UNITED 57A?f s \\ ), < . NUCLEAR REGULATORY COMMISSthN i i REGack tv P. i PARKWAY CEn/ TRAL PLAZA ButLotNG ~ / 611 RYAN plt.2A ORIVE. SutTE 1000 ARLINGTON. TEXAS 70011 v '.i '. 's P;Mi Recional Office Policy Guide No. C101 Revision 1-COMMUNICATIONS REGARDING ITEMS OF IMMEDIATE INTEREST ' A. Purcose: To provide guidance or significant or potentially.significant event.s which should be brought to the prompt attention of the Director, Division of Radiation Safety and Safeguarcs. B. Discussion: Division management needs to be informed of certain events that are reported to the Division staff members and supervisors, in order to ensure that the appropriate action is, or has been, taken and to inform the Regional Administrator, if indicated. C. Action: 1. The staff members receiving the information either in writing, g observation by the inspector (s), or orally shall immediately inform his or her supervisor. 2. The Branch Chief shall promptly inform the Division Director. 3. Oral information shall be followed up with written documentation if requested by the Division Director or called for by Region policy; e.g., allegation documentation. 4 Regional poHcy guides and procedures are to be followed where applicable in formally transmitting information concerning certain events outside of the Regional Office; e.g., daily reports, PNs, staff notes, and escalated enforcement. 5. The enclosure, althugh' not all inclusive, contains a list of the type of events to be reported pursuant to the policy guide. i I 6. Certain items on the enclosure are of particular interest and must be reported upon first evidence of their ptistence or sotential existence. These include any indication of wrong-doing or inspection findings which appear to warrant escalatej enforcement action, any indication of items that could represent an immec. ate threat to safety, and allegations. If such inforna-tion is discovered during en inspection, the inspector (s) should 1 i t
3 .s -1 g, q, = b:
- a. ::
o @ 'lC C i d,e ?.:: ;ecO< g 1 % ys ( v 1 h w. 1 ir eciatey contact r.is immediate supervisor by telephone and 0-esent it/% facts as known. Subsec',ent discussions with the Director of the Division of Radiation Safety and Safeguards will decide the need for immediate notification to the Region [ Administrator's office. 3. C or. ta c t : s,. Suggestions'or comments should be directed to the Of rector, Division of Radiation Safety and Safeguerds, extension 249. E. Effective Date: -s This Ptility Guide supersedd Regional Office folicy Guide No. 0100, Revision 0, datec January 15, 1985, and is in'effect when issued. r.
- s.
ll thld \\ t' L fit uj d t { [ RichardL.Bangart,Diredtr Division of Rrdiat(on Safety and Safeguards i
Enclosure:
List of Events Reauiring Reporting Distribution: E i i e I \\ i l 1 I u_--------_---_-.
F ~. l DC.01.RE J'A " 31985 -. ' yT Ol jjEyT1 3 u4_ U Q REf;g ;RG l Overewoosure to wo'iers or public release (s) of radioactive material to t-t environment which exceecs regulatory limits or requires special reporting pursuant to license conditions, technical specifications, or regulations l .,>i
- i. Transportation incidents
~^ Loss of radioactive material in the public domain 2. j. 4 Exceeding limiting conditions for operations 3. Medical therapeutic misadministration 6. Threats of/or an actual act'of sabotage 7. Potential FEMA Category A deficiencies ~.~ 8. Significant inspection findings, such as immediate health and safety concerns, and need for Confirmatory Action Letter t 9. Any incident report required by 10 CFR 20.403
- 10. Allegations
- 11. Media contacts or any event which may be of media concern i
- 12. Peter.tial escalated enforcement action
- 13. Contacts from offices of elected officials
- 14. Matters involving potential wrongdoing or willful noncompliance on the part of licensees i
i 4 i l l l l l l
ATTACHMEf41 3.8 R0PG 1303 Implementation of Open Item Tracking System for Resident Sites arid Regional Office (Rev.1) l, I l 1 Y l 1
mw,; ;
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,- ~ - - - ~..s ~~ ~~~~ ~ ~ ~ * * " ~ ~ " ' " " " " ' ' " " " * " " " " ", " " " " ' ' ' " " ' " " " " " " " " ' ' ~ ~ ~ ~ " " ~ ~ ~ " ' " ~ ' g ** ' uNITEo STATES /s NUCLEAR REGULATORY COMMISSION p i e( ie e, c REGION IV ~ [/ t .f $11 RY AN PLAZA oRIVE, SufTE 10iio ARUNGTON. TEXAS 70011 SEP 0 4 666 Regional Office Policy Guide No. 1303. Revision I IMPLEMENTATION OF OP2N ITEM TRACKING SYSTEM FOR RESIDENT SITES AND REGIONAL . OFFICE A. Purcose: This guide is issued to implement the Open Item Tracking System for the resident sites and Regional office. This guide delineates responsibilities and provides complete instructions to Region IV personnel for entering new open items and updating information into the tracking system. B. Discussion: The Open Item Tracking System provides a means for tracing and accounting for all open items associated with the design, construction, pre-operational testing and operation of reactor facilities. 3 The method described herein applies to Violations, Deviations, Deficiencies, Unresolved Items, Bulletins, Information Notice, LER's, 50.55(e) Reports, Part 21 Reports, Open Items, Temporary. Instructions, 1 Safety Evaluation Report (SER) items, NRC Generic Letters, Special i Transmittals, CALs and miscellaneous inspection-related items which must I be tracked and followed up in subsequent inspections. I l C. Responsibilities: l I. The Open Item File (OIF) is 4 data file maintained in the RIV IBM 5520 system. The File Manager (Chief, Information Management Section) is responsible for controlling file access and updating the files. A separate, but functionally identical file is established for each of the participating sites. The files for two sites will be updated weekly as indicated on the attached schedule so that all files are updated about once each month. (See Attachment I) 1 2. The Project Inspector for the specific site is responsible for the review and audit of the Open Item Tracking List. Open Items will go to the Project Inspector who reviews the input for obvious discrepancies or omissions, resolves any problems found, acts as the collection point for new items / updates and then forwards the new open items / updates to the File Manager.
' i l I \\ Regional Office policy Guide SEP 04 585 ) No. 1303, Revision 1 1 D. Content: 1 'All new open items are reported on an update Form. (See Attachment 2). All closed items are to be updated on a marked up printout. The following describes the meaning, content, and use of each of the fields on an individual OIF field. (See Attachment 2) i 'l. Name of Oricinator A 20 character field is used to identify the responsible inspector or individual responsible for providing the data update form. This field will be completed, listing the last name first, then the first initial., j Example: Johnson, E. 2. Type This one character field is used to identify the category of the open . items. The letters identified below are used to complete this field: o B = IE Bulletins o N = Information Notice
- C = Confirmatory Action 0 = Open Item Letter (CAL)
- P = SALP Item D = Deviation o R = Part 21 Report a
- E = 50.55(e) o S = Special Transmittal F = Inspector Followup o G = NRR Generic Letter o T = Temporary Instructions H = Deficiency
- L = Licensee Event U = Unresolved Item Report (LER)'
V = Violation o M = Miscellaneous
- Z = Safety Evaluation Report (SER)/
Supplemental Safety Evaluation Report (SSER) NOTE: The items marked with a "*" are normally the responsibility of the Reactor Projects Branch. The items marked with an "o" are normally the responsibility of.the Reactor Safety Branch including those items which will require followup by the Division of Radiation Safety and Safeguards. The update forms for open items, unresolved items, violations, f deviations, deficiencies, and inspector followup items will be prepared by the inspector performing the inspection. l. )
s,;---- I ? Regional Office Policy Guide -. $[pg4 gg Nc. 1303, Revision 1 3, Item No. This 10 character field is used to identify the open item., Examples are: 83-002, 83-014, 8516-002. (Items documented in inspection reports for tracking, e.g., violations, deviations, etc.) 4 Report This six character field indicates the number of the inspection i report that opened the item. Standard inspection report numbers 85-01, etc., are used for this field. Items such as LER's, IEBs etc., that were not opened in a report, are to be left blank. 5. Paraarap'h This four charactea field is used to identify the specific paragraph in the report that covers the item. 6. Functional Area i l This 20 character field is used to reference the followup item in a SAlp functional area. The entry for this field will be the title of the SALP functional area, and will generally only have entries for ( deviations LER's, and violations. This field is left blank if the y information is not necessary. 7. Description This field consists of three - 20 character lines and is used to describe the followup item. 1 8. Status Code i This one character field is used to indicate the status of the item. (0 = open, C = closed) 1 1 9. Update /Close Inspection Report j This 20 character field is used to record the inspection report number and the specific paragraph in the report that contains either the final closecut information on a closed item or for interim j followup information for an open item that has received some { inspection but is not yet closed. l h
-..a.:.... ~. - -~ ~-~~------O J Regicnal Office Policy Guide ~ No. 1303, Revision 1 10. Responsible Section j This 10 character field indicates the organizational section l j responsible for closing the item. The following entries will be used { for this field: { RPSA (Reactor Project Section A) RPSB (Reactor Project Section B) RPSC (Reactor Project Section C) .ES (Engineering Section) 05 (Operations Section) OLS (Operator Licensing Section) FRPS (F.acilities Radiation Protection Section) NMSS (Nuclear Materials Safety Section) EP&SPS (Emergency Preparedness and Safeguards Programs Section) EO (Enforcement / Allegations Staff)
- 11. Details These fields consists of a combined 1000 characters and are used for any text information that is desired. For LER's, this field will be used to list causally-linked LER's. The name of the individual who opened the item is recorded here if different from the originator.
In general, any.useful information can be included in this field. This field is not normally printed in management summary reports. E. Procedure for Enterino items Into the File: The update form ( Attachment 2) is used to add new open items into the file. The form can be handwritten, but it must be legible. The completed form is forwarded to the originator's supervisor. These items which are generated as a result of inspections (e.g., violations, open items, etc.) will be prepared and included with the draft of the inspection report. The supervisor is responsible for forwarding the form to the open item Project Inspector for review and audit. For open items identified during an inspection, the update form will be forwarded to the Project Inspector after the report has been signed off by the Branch Chief and forwarded for reproduction and distribution. The form is then sent to the File Manager in accordance with the prescribed schedule. After the file data is entered, a printed copy of the file will be returned to the originator. F. Procedure for Changing An Entry: Revisions or updates to a file will generally be made by marking up (in red ink) a copy of the printed file update form and forwarding it to the
1 I 'li \\ ' I Regional Office Policy Guice N N O' Ne 1303, Revision 1 Project Inspector. the marked up file will be-submitted with the inspection reportF update form will be given to the Project 1.nspector af ter the report is The signed off by the Branch Chief. same schedule for file input as new items. Revisions and updates will follow the G. Summary Printout Formats: Updated summary printouts will be promptly distributed to the appropriate Reactor Projects Branch, with one copy to the Reactor Sa copies to the ' Emergency Preparedness and Safeguards Programs Section of , three Protection Section of only FRPS open items.only EP&SPS open ite H. Effective Date: This Policy Guide supersedes Policy Guide 1303, Revision 0, dated March 11, 1986, and is in effect when issued. C RobertD. Martin Regional Administrator 1 Attachments: As stated f Distribution List C 8 I
1 CEP ; 4 h6 ~ ATTACHMENT 1 SCHEDULE WEEK 1 AN0/FSV WEEK 2 WAT/FCS ~ WEEK 3 STP/ COOPER WEEK 4 WC/RB e e l \\ l'
,~ LEt ; a t3 ATTACHMENT 2 ~ ~ o UPDATE FORM FACILITY: DOCKET: ORIGINATORS _ NAME: 00O00000000 ROD 00000O TYPE: O ITEM NO.: 00000O0000 ^ REPORT: D00000 PARAGRAPH: OOOO FUNCTIONAL AREA: 00000000000000000000 l DESCRIPTION: 000000000000000000D0 000000000000000000D0 000000000000000000D0 STATUS CODE: O i UPDATE /CLOSE PARA / REPORT OOOOO00000N000OOGD0 RESPONSIBLE SECTION OOOOOODOOO DETAILS: j F
..._..____.____<.~~%__.....,_~.sx.... ATTACHMENT 3.C R0PG 1320 Centrol of Outstanding Action Items 4 i l e 4 l l l l J
' /j.* c, p [,'. l.,* * ( UNITC D sT AT Es t.UCLE AR R E GUL ATORY CO:.*!.*:SS!Of.' t-REGION IV [ f,11 RYAN PL AZ A DMVf. ; UtiL'iC?0 ,o' A R L t!.C.10 *.. i t '. t'. 7C D 11 ....+ SSINS 0250 ' Regional Office Policy Guide No. 1320, Revision 0 CONTROL OF OUTSTANDING ACTION ITEMS i A. Objective 1. The Open Action Items List will provide a method of traceability and accountability for all open items generated during the inspection of design, procurement, construction, and operation of reactor facilities. If directed by the Director, Division V&TP, it may also be used for tracking Materials Program and Vendor Program items. 2. The method described herein applies to Violations, Deviations, Unresolved Items, Bulletins, Circulars, LER's, 50.55(e) Reports, 1 Allegations, Part 21 Reports, Open Items, Temporary Instructions, and other miscellaneous items. 3.-
Reference:
IE Manual Chapter 1005, " Inspection Reports," March 28, 1977. B. policy 1. Responsibilities a. The Section Chief assigned responsibility for a licensee or vendor is responsible for the periodic review and audit of the Open Action Items List for that licensee / vendor or reactor licensees. He will monthly transmit the Open Action Items List to the Resident Inspector. The Section Chiefs are responsible for ;nitial input of the following: Bulletins, Circulars, 50.55(e) Reports, LER's, Part 21 Reports, Miscel-laneous Items, and Temporary Instructions. i b. The lead inspector for an inspection is responsible for the preparation of Form 0Al-1 (Attachment B) for new items' ider.tified (updated)' or closed during his inspection. A marked up printout of the current Open Action Items List may be used in lieu of the Fonn OAI-1 at the discretion of the responsible.Section Chief. i
begior.a1 Offite. Policy Guide _. No. 1320, Rev
- 0. The completed' Form OAl-1 and/or marked up' computer printout, when applicable, should be attached to the final inspection report with 'the original SF 766 and submitted to the MIS' staff when the ' report is issued to the licensee / vendor, Allegations will be entered into the system by the submittal c.
of a Form 0Al-1 (or marked up printout) by the inspector or supervisor receiving the allegation. The identification number-for' the allegation will be obtained from.the Director IES. A completed Form 0Al-1 (or marked up printout) will be submitted with the investigation or inspection report that closes out the allegation. 2. Procedure All open items will be reported on Fo m 0Al-1 or a marked up computer printout. a. Heading Enter the date and the docket number. b. Type item (Column 1) i' Utilize the symbols identified on Form OAl-1, "Open Action Items List"; i.e., A = Allegation B = Bulletin C = Circular D = Deviation E = 50.55(e) L = LER H = Miscellaneous 0 = Open Item q t R = Part 21 Report i T = Temporary Instructions U = Unresolved Item V = Violation c. Item Number (Column 2) 1 For Violations, Unresolved Items, Open Items, and Deviations, use the report number plus sequential arabic numbering as requi red; i.e., 8201-01, 8201-02, 8201-03, etc. There should
.._m..._...._____......_........_,-..._. 1 1 Pegional Office Policy Guide t;o. 13 0, Fev. 0 -- te only one unique number per item. For other items, enter first the same symbol as used in Column I, then the year, followed by a dash and the sequential number for that year; i.e., L82-01, E82-01, A82-01, M82-01 L82-02, etc. For TI's, enter the same symbol as used in Column 1 plus its assigned number; i.e., T2500/05. T2515/41, T2515/43, etc. Other notations may be added to denote subsequent submissions of the same document; i.e., B82-01 IEB 82-01, Initial B82-0151 IEB 82-01, Supplement 1 B82-0152 IEB 82-01, Supplement 2 E82-01 50.55(e) Report 82-01, Initial E82-OllNT 50.55(e) Report 82-01, Interim E82-Olf 50.55(e) Report 82-01, Final d. Report Paragraph (Column 3) Enter the paragraph number in which the item is identified in the inspection report, if applicable. e. Responsible Section (Column 4) 3 Enter symbol identified below for the section or organization of the principle individual who originally identified the open item. PB-A = Reactor Project Branch 1, Section A PB-B = Reactor Project Branch 1, Section B PB-C = Reacter Project Branch 2, Section C PB-E = Reactor Project Branch 2. Engineering Section V-RC = Vendor Program Branch, Reactive & Component V-RS = Vendor Program Branch,' Reactor System V-EQ = Vendor Program Branch, Equipment Qualification T-MR = Technical Program Branch, Materials & Radiation Protection T-RP = Technical Program Branch, Facilities Radiation Protection T-PS = Technical Program Branch, Physical Securitv s El-1 = Investigators f. Module (Column 5) Enter the inspection module number, if applicable. For LER's, enter the type report in the Module Column; i.e., 03L-0, OlT-0., etc., to denote 14-day and 30-day reports. l l
l. p Regional Office. Policy Guide rio. 1320. Rev. 0 g. Description (Column 6) 1 i L Brief. surmiary of open item. Other information as deemed appropriate should'be entered-in this column, such as, response due'date, etc. With regard to-Bulletins and-Circulars,.the format has been fixed. The first three lines are the title of-the Bulletin or Circular and the next three are as follows: Reply Due Date: Reply Received Date: Closeout TI: With regard to LER's, the title is entered in the first two lines and the. remaining. four lines are. structured as follows: i Event Date: l Telephone Report Date: ^ Confirmation Date: Report Date: h.. Update /Closecut Report (Column 7) l Enter the inspection report number on a current computer printout on the appropriate line to identify that an item is being closed. If an item was inspected but not closed out, enter the report number within brackets; i.e., (82-01); do not make an entry in Column 8. 'i. Status Code (Column 8) Enter C when the item is closed. An item does not necessarily have to be closed out in an inspection report. The entry of the C will remove the item from the printout of outstanding items. A permanent record of all closed items is maintained and may be recalled if desired. 3. Handling of Specific Inputs a. Licensee Event Reports The initial input for LER's is taken from the entry in the Gray Book each month by the MIS staff.
[l ._.._........e........._._,,_._....._...-.__.~._.___._..._- R .;........fl.ZT l. l~ .: Regioriai.Lf fice Policy G.;ide No. 1320,3ev. 0 - fr-- b. Bulletins and Circulars The initial input.for the Bulletins and Circulars is taken from the cover sheet prepared.by Branch Secretaries on. distribution of the Bulletin or Circular.- The responsible Reactor Project Section. Chief is responsible for providing a copy to the MIS staff. (See Attachment A). c. 50.55(e) Reports', Part 21 Reports, TI's, and Miscellaneous Items The Section Chief responsible for a licensee or vendor will prepare the Form 0Al-1 (or mark up a printout) for these items and submit them to the MIS staff for input to the Open Action Items' List, i l .C. . Effective Date This Policy Guide is in effect when issued. ~ .A .g John T. Collins '9 Regional Administrator, Distribution List AB
' ::. /.-1 ATTADC4E'[T A' IE Ci".LET:li/ClRCUL AR STATUS TCR.'.: S 1. Facility: _~ 2. Docket #: 3. IE Bulletin / Circular Title & Number: i 4 Date Transmitted to Licensee: 5. Reply Due Date: i ) 6. Reply Received: 7. Inspection Report Closecut: 8. Date of Closecut: 9. Closecut of any Associated TI:
- 10. General Information Relative to IE Bulletin / Circular:
I 2
L. - rp O ~tt e F s rst u onI t o pI u e e d c nmR yen e ae r s a l'v o l t1 o i l I 2 rot l e osa C cnt pel / sermro et) i paeni t r0 M0PTUV ao3
= = = =
7 d p( M0RTUV pe UR no n i nro) ti aie atl t( geua5 el c i 5. R rv l l l uie0E ABCD5L e
= = = =
ABCDEL e T d S o I C n L o e i B S p t M y p) T E T i6 N T r8 E I 6 c1 M s( l N e Q O D A I T T e T C A A ) 1 e N ( l E u) P n 5 d7 O i o( M n w o h s e l y b r i t sn n no e oi) 4 pt4 h sc( c ee a RS e r o f d h e p w a o t r l rg) l 3 oa6 a pr( ea s RP r ) e 8 t ( ca r m.) a h e c 2 t io8 I r( x lo a M f t e e k e em t c t 1 pe) a o yt i N 1 TI i
T1 ~ 1 "" "' N, . UNITED STATES / t NUCLEAR REGULATORY COMMISSION ik . {r REGION IV ',,[/f 611 RYAN PLAZA DRIVE. SUITE 1000 ARLINGTON. TEXAS 76011 July 13,1982 MEMORANDUM FOR: All RIV. Personnel i 'FROM: John T. Collins, Regional Administrator
SUBJECT:
CONTROL OF OUTSTANDING ACTION ITEMS - POLICY GUIDE 1320-1 a The attached policy guide (PG-1320) is transmitted for imediate implemen-tation. This policy guide will be used by all branches.and by IES to track those items (violations, deviations, bulletins, etc.) at reactor facilities which will'. require subsequent follow-up and closecut. The existing 01 list will not have to be updated to pick up the outstanding ' items in the new category of items to be tracked, but effective this date, all newly identified items will be entered on the 01 list. $w/ f.$f& John T. Collins Regional Administrator 2
Attachment:
As stated 1 i l
4 Form-NRC-1 (R:V-1/82) U.' S. NUCLEAR REGULATORY COMMISSION REGION IV TRANSMITTAL SHEET FOR POLICY GUIDE AND/0R NOTICE Policy Guide No. 1320 - CONTROL 0F OUTSTANDING ACTION-ITEMS TRANSMITTED: SUPERSEDED: Policy Guide No. 1320 pey, 0 Policy Guide No. NA Series . Notice No. NA Rev. Dated: No. of Pages - 7 Distribution AB j .' g'. (A-Administrative Staff; B-Professional; AB-All Employees) REMARKS: The purpose of this guide is to provide complete instructions to Region IV personnel for the traceability and accountability for i all open action items. 1 d I { Prepared by:' rd \\ ' Approved by:
- 1/
O
- \\(Signattre )
/ (Signature)
Title:
Director Division of Resident.itle: Regional Administrator 'N Reactor Project a engineering Programs Date Approved: 7Me//v ) a
(" Wh M M P P.= we =, w l ] 'l F I I l 1 1 1 ATTACHMENT 3.D a mes 1 R0PG 1002 Enforcement Conferences (Rev. 2) k 1 '1 O l l
N, ';NITED STATES f-g NUCLEAR REGULATORY COMMISSION h 5 REGION IV h,,,,, #[ 'r 611 RYAN PLAZA oRIVE. SUITE 1000 ARLINGTON, TEXAS 75011 DEC 2 21986 Regional Office Policy Guide No. 1002, Rev. 2 ENFORCEMENT CONFERENCES A.
Purpose:
To describe the purpose for holding enforcement conferences, the' associated necessary coordination among staff, and the manner in which enforcement conferences will be documented. This Policy Guide supplemer.ts that guid-ance given in Policy Guide No. 1901. ~ B. Discussion: When NRC becomes aware of a potential violation or particular situation for which a civil penalty or other escalated enforcement action may be warranted, the NRC will normally hold an enforcement conference. The enforcement conference will be held prior to the issuance of an order or a Notice of Violation that cites a Severity Level I, II, or III violation or numerous Severity Level IV ur V violations that collectively warrant an enforcement conference. However, when needed to protect the public health and safety or comon defense and security, enforcement action such as the issuance of a confirmatory action letter or an imediately effective order modifying, suspending, or revoking a license may be taken prior to the enforcement conference. The purpose of an enforcement conference is to: (a)discussthe violations, their significance and root causes, and the applicant's or licensee's corrective actions; (b) determine whether there are any aggravating or mitigating circumstances; and (c) obtain information that will help NRC determine the appropriate type and level of enforcement action. During the course of NRC's interaction with the licensee, certain predecisional information developed by the NRC should not be released to the licensee. Infonnation, but not predecisional documents, identifying potential items of noncompliance is appropriate for release to the licensee to assure corrective actions are initiated to obtain compliance. The severity level of a violation or the nature of an escalated enforcement actinn may chanp', however, during the review of the matter in the Region and/or at Headquarters. This is especially true regarding those matters on which the Commission must be consulted before taking enforcement action. Therefore, predecisional information regarding such things as potential severity level, civil
DEC 2 21985 e Jegional Office Policy Guide No. 100?, Rev. 2 ~ penalty amount, or nature / context of an order are not appropriate for discussion with the licensee without the concurrence nf the Director, Office of Inspection and Enforcement. C. Action: 1. Inspector: The field inspector should promptly notify the imediate supervisor or the first available member of line management when an apparent violation is discovered of sufficient significance that escalated enforcement action may be warranted. This is especially important wher the noncomplying activity or conditi0n is likely to persist. 2. Division /URF0 Director: Division /URF0 management will brief the Regional Administrator and the Enforcement Officer on all inspection findings of escalated nature at the time of notification or at most one or two days following the return of a region-based inspector to the Regional /URF0 office. Potential escalated ertforcement cases against utilities or reactor licensees that are identified by DRSS personnel should also be brought to the attention of the Reactor Projects Branch Chief. Potential escalated enforcement cases iden-tified by URF0 personnel will also be brought to the attention of the Director, DRSS by the Director, URF0. 3. Regional Administrator: The Regional Administrator will decide 9 whether to hold an enforcement conference and, if so, which level of Regional management will conduct the conference. (Note: Upon receipt and review of reports from the Office of Investigations, the Regional Administrator may decide that an enforcement conference is warranted without having the Region first conduct an inspection.) 4 Division /URF0 Director: Division /URF0 manacement coordinates with the applicant or licensee and the Regional staff including the Enforcement Officer to schedule the enforcement conference, which will nomally be held approximately four weeks following the inspection finding and 3-5 days after licensee receipt of the issued inspection report. The inspection report transmittal letter will normally confim the date and time of the enforcement conference. Division /URF0 management will route a Notice of Significant Meeting through the Division (s) and the Enforcement Officer for concurrence. The letter transmitting the Notice will also contain a proposed agenda for the enforcement conference. A Daily Report and Daily Staff Note will be prepared and submitted to the Regional Administrator for approval the day before the enforcement conference. If, subsequently, an enforcement ennference is cancelled or rescheduled, the Daily Report and the Daily Staff Hote should be changed. Those changes can be made providing that the changes are given to the Regional Administrator's secretary prior to 8:00 a.m. on the day of the enforcement conference.
l DEC 2 2 E Regional Office Policy Guide ; e No.1002. Rev. 2 5. Enforcement Officer: The Enforcement Officer will place the enforcement conference on the IE Enforcement Staff status calendar. 6. Assigned Regional Manager: The assi conduct the enforcement conference. gned Regional manager will Attendees at the enforcement conference will be specified by the assigned Regional manager. Enforcement conferences are nonnally closed to the public. (Itis customary that the senior corporate member of a utility attending an enforcement conference in the Regional Office to have a short exit meeting with the Regional Administrator following the conference.) Following the enforcement conference, an enforcement panel will be convened. The panel should meet as soon as possible after the enforcement conference, preferably the same day or the next working day. The panel will normally be chaired by the assigned regional manager and constituted by other involved regional supervisors, any attendees from Headquarters, and the Enforcement Officer. The purpose for the panel will be to discuss the licensee's'rasponses' to the inspection or investigation findings and to discuss the enforcement options that are deemed appropriate. The panel's ~- t recommendations will be simultaneously (1) offered to the Regional 4 Administrator for approval and (2) provided to the regional staff member who is charged with drafting the Notice of Violation, Notice of Violation and Proposed Imposition of Civil Penalties, or Order. t 7. Division /URF0 Director: Division /URF0 manacement will prepare a. meeting sumary of the enforcement conference. The summary will include the following. 1 A list of attendees and their affiliations and/or titles. a. b. Issues discussed. c. Significant conclusions or positions. d. An attachment of handouts or transparencies shown at the meeting. If 10 CFR 2.790 information was presented, this should be sanitized on a separate enclosure and proper markings applied to the proprietary material. If the entire meeting was 10 CFR 2.790 information, the transmittal letter should make this clear. In this case both documents are needed since the letter will go to the POR but the 2.790 enclosure will not. Similarly, if the material presented contains safeguards information as defined by 10 CFR 73.21, then the material will not be placed in the Public Document Room. l I 1
EE; ;2 We ,:egional Office Policy ~ Guide ' ~ No. 1002, Rev. 2 l The meetino sumary will be transmitted to the licensee in accordance with the provisions of Policy Guide No. 1901. For some situations, it may be more appropriate to issue the meeting sumary separately as an inspection report. 8. Enforcement Staff Secretary: If, following an enforcement conference, i the staff decides to pursue escalated enforcement, then the inspection. report and the reeting sumary will become background material to an escalated enforcement package. Therefore,.the IBM 5520 addresses of these documents will be retained by the Enforcement Staff Secretary for subsequent transmission to 0IE. D.
Contact:
Suggestions of coments should be directed to the Enforcement Officer. l ~ 'E. Effective Date: This Policy Guide is in effect when issued and supersedes Policy Guide No. 1002, Rev. 1. p ./ / / \\ ,7 I 7 c.<. Robert D. Martin Regional Administrator Distribution List AB l 1 l l l i I
. - -... ~...... I i l \\ l l ATTACHMENT 4.A l' R0PG 2200 Communications Regarding Inspections (Rev. 0) Ot i i
l , pt ** * %, CNITEo STATES ~ [., / NUCLEAR REGULATORY COMMISSION I ~ 7,,, ~ REGION tv k'S $11 RYAN PLAZA oRfVE. SUITE 1000 9, ,8 ARLINoToN. TEXAS 70011 DEC 211984 Regional Office policy Guidt No. 2200(3), Revision 0 COMMUNICATIONS REGARDING INSPECTIONS A. purpose: To describe the procedures to be followed by regional staff members to keep the Olvision of React 9r $afety and projects (Projects) informed of planned inspections, and to assure that they are informed of inspection findings following inspections. B. Discussion and Action: 1. Notification of Planned Inspections - Prior to performance of inspections at nuclear power reactor facilities, inspectors of divisions,other thaa the Projects Division and inspectors from Projects Sections other than the one respons,ible for the facility, will submit a j .. ~ form similar to that attached (attachment) to the responsible Projects section chief. Whenever practical, this form should be submitted at least I week prior to the planned inspection. Changes to the submitted plan should be verbally communicated to the E-responsible Projects section chief if they are significant. As an alternative to submission of the form shown in the attachment, a copy of the travel request may be submitted to the same distribution as shown for the attachment. 2. Exit Meetings - To the maximum extent possible, the exit meetings for all inspectors at a given facility during each week shall be coordinated by the senior resident inspector and held jointly, normally on Friday afternoon. The senior resident or his alternate will attend all meetings. 3. Inspection Findings - Following debriefing of the inspector by his regional section chief, that section chief shall discuss the inspection findings with the responsible Projects section chief, no later than 2 working days following return of the inspector to the region. This briefing shall include a discussion of each violation or deficiency identified and the possibility of escalated enforcement. The status of open items and other inspection findings may be deferred until the inspection report is prepared. o
y p, M 2'- 2 C. ' Definition: This policy guide is not applicable to regional supervision accompanying inspectors for supervisory evaluation. O.
Contact:
ti None applicable. E. Effective Date: This policy guide is effective when issued. h 4 i Robert D. Martin Regional Administrator-
Attachment:
- planned Inspection Form Letter Distribution. List AB. S
l' - T I ]c ** ""f \\; ~ e UNITED STATES e, o. o NUCLEAR REGULATORY COMMISSION. ,ei g 8' REGION IV k 411 RYAN PLAZA DRIVE. SUITE 1000 Attachment ~ ARLINGTON. TEXAS 70011 l-MEMORANDUM FOR: , Chief, Reactor Project Section, THRU: , Chief, Section FROM:
SUBJECT:
PLANNED INSPECTION - The subject inspection will be conducted by during the period to This inspection will be in accordance with NRC Inspection Procedures and has been assigned NRC Inspection Report No. 5 The Resident Inspector, -was informed by telephone on of the inspection. The estimated time cf arrival is on Lead Inspector cc: Director, DRS&S Director, DRS&P Branch Chief, RPB1 4 Branch Chief, RPB2 ) I Branch Chief. EP&RPB Branch Chief, NMS&SB bec: Inspector Section Chief Branch Secretary I l
ATTACHMENT 5.A R0PG 2205 Supervisory Accompaniment of Staff (Rev. 0) i Ae I l
j#" UNITED STATES 7,,, NUCLEAR REGULATORY COMMISSION l REcioN iv I -4 $11 RYAN PLAZA DRIVE. SUITE 1000 %,,{,, # ARuncToN. TEXAS no11 MG 261985 Recional Office Policy Guide 2205; Revision 0 SUPERVISORY. ACCOMPANIMENT OF STAFF A. Purpose i To promulgate regional policy on the accompaniment by supervisors of the regional technical staff during performance of inspections or other field functions. B. Discussion Supervisors should assure that they are aware of the working conditions and performance of their staff. Therefore, it is necessary that supervisors accompany their staff periodically to obtain this feedback and to counsel and advise their staff members on actions they could take to improve their performance. Such direct observations also enable the supervisor to determine more accurately those staff members whose . ~ ~ perfomance is deserving'of rergnition. One intent of this policy guide is that first level supervisors accompanying each of their employees 1.nto the field it least once each year. C. Action l The following policy is established, provided adequate travel funds are available during the fiscal year: 1. Branch chiefs from the technical divisions will accompany at least one of their subordinates (i.e., section chief, regional inspector, or resident inspector) in field activities not less than once a calendar quarter. This requirement applies only to permanently assigned branch chiefs, and is not applicable to supervisors in an " acting" capacity. The branch chiefs in'URF0 shall accompany at least one of their staff on licensing or inspection visits not less l than an average of once every two months and visit each assigned site or meet with management of each licensee at least once each year. 2. Section chiefs shall accompany their staff members in the following fashion: Section chiefs in the DRSS Division shall accompany inspectors a. on field inspections not less than once every two months. b. Section chiefs in the Reactor Projects Branch of the DRSP Division shall visit one of their assigned sites not less than l' ( i
l Regional Office Policy Guide'No. 2205, Revision 0 AUG 2 61c85 l once per month and visit each assigned site at least twice a yebr. c. Section chiefs in the Reactor Safety Branch of the DRSP Division l shall accompany one or more of their inspectors not less than ] once every two months and shall visit each site at least once every two years. d. The section chief of the Operator Licensing Section shall._. accompanying one or more of their operator examiners not less than once every two months and shall visit each site at least once every two years. 3. Accompaniment by branch and section chiefs are to be 2-3 days in duration. This guide should not be interpreted to require full week accompaniment, except in unusual cases. Supervisors will not norttially be expected to perform direct inspection during accompaniment, but on occasion may document inspection or participate in licensee meetings, if appropriate. D. Contact Coments regarding this policy guide should be directed to the Regional Administrator. E. Effective Date-This policy guide is in effect when issued. m. c. l /El Robert D. Martin Regional Administrator Distribution List: C k i
ATTACHMENT 6 Documents listed in Section 6. 1 l 1 f l l l
- ~~ -.- ~ \\ ' -. . ~ a
- "8 4 UNfftD STATES 9
k
- t NUCLEAR MEGULATORY COMMISSION
~ ~ .,[ ' l1 i } naosoN IV [ o PARKWAY CENTRAL PLAZA BUILDING L %.,Y. / '""a"JoTN #716'#2 ** l MAY 61985 1 'Recional Office Policy Guide No. 0211. Revision 0 ' POLICY ON CONTROL OF NRC REPORTS AND OTHER DOCUMENTS AND O! REFERRALS A.
Purpose:
NRC must act promptly and positively on nuclear safety and safeguards concerns. Such concerns must be identified promptly, documented, and made known to responsible licensee management to obtain prompt evalua-tion and appropriate corrective action. At the same time, NRC documents must be developed and issued without improper licensee or public influ-ence, or in the appearance thereof, and must be made available to the public in a timely manner, consistent with NRC regulations, policies. and procedures. B. Discussion: The objectives of this policy statement with regard to both plant-specific and generic NRC reports and other documents (referred to hereinafter as ~ " documents")are: 1. To provide NRC staff with general policy guidance on the release and distribution of draft and final documents. 2. To assure that staff documents are developed and issued without improper influences, real or perceived, by the public or by applicants, licensees, permittees or their subcontractors or agents i (referred to hereinafter as " licensee") and are made available promptly to the public. 3. To assure that the Office of Investigations (01) is promptly informed whenever a material false rtatement is suspected. l 4. To assure that matters being referred to 01 should be coordinated with 01 prior to advising a licensee of the potential referral. 5. To assure that sufficient flexibility is provided to Office Directors I and Regional Administrators so that they and their staffs will not hesitate to disseminate appropriate safety or safeguards infonnation to licensees, before distribution of final documents. I
- Regional Office Policy Guide No. 0211, Rev. 0.
MAY 6 1985 C. Action: 1.- For the purpose of this policy, the term " documents" encompasses all written material considered to be NRC records under 10 CFR Part 9. A draft document is to be considered a draft from its initial development throughout the period of review until its issuance as a final document. A final document is'one that has been signed or otherwise approved for publication and distribution. Final documents will be distributed in a manner that will ensure that the public, the licensees, NRC contractors, and Government agencies have access to information they need to fulfill their responsibilities. Final documents provided to licensees will be placed in the Public Document Room (PDR). 2. Any decision under this policy to place documents in the PDR must also be consistent with NRC regulations, policies, and procedures i regarding confidentiality, security, safeguards, proprietary, and ' Privacy Act Information and investigative matters. 3. Draft documents, or information contained therein, are not to be / j 9 discussed with, given to, or shown to any licensee or the public by NRC staff without prior approval by the Regional Administrator; nor should potential referrals to 01 be discussed with any licensee or ( the public by NRC staff prior to coordination with 01. 4. Predecisional interagency or intraagency memoranda and letters shall not be provided to licensees or the public or placed in the PDR without prior approval by the Regional Administrator. 5. In the event any document is inadvertently or otherwise released by 1 the. NRC, its contractors, or other Government agencies contrary to j this policy, the EDO should be advised promptly in writing of the ( occurrence and the corrective action to be taken by the responsible ) office to avoid recurrence of such release. Nonnally, under such 1 circumstances, the released document should be placed in the PDR. f 6. The Director of the 01, RIV, Field Office shall be promptly informed by the RIV Office Allegation Coordinator (OAC) whenever a material false statement is suspected. 7. Any matter being referred to 01 should be coordinated with 01 prior to advising a licensee of the potential referral. D. EXCEPTIONS 1. In the event there is an emergency, or a significant safety er safeguards issue appears to require immediate action, NRC personnel, at their discretion, may discuss with, show to, or provide the licensee with any pertinent material they believe the circumstances warrant.
__....._._m.. t,. L L Regional Office Policy Guide MY 6 M5 No. 0211, Rev. 0 2. In the normal' course of conducting regulatory activities, connunications with licensees, vendors, industry representatives, i and other Government agencies are at times necessary regarding initial NRC staff positions, license condit'ons, confinnation of action letters, inspection findings, preparation of bulletins and infonnation notices, events at other facilities, etc. Such connunications can be held in advance of f he final NRC documents for the purpose of (1) gaining factual in/onnation; (2) ast.essing the cost, feasibility, and benefit of, ce alternatives to, proposed actions; or (3) alerting licensees to initial staff positions or safety findings in order that corrective actions can be initiated promptly. This policy statement is not intended to impede such exchanges of infonnation. Any written connunications provided by i the staff to licensees or the public shall, however, be placed in the PDR. 3. Draft research reports, studies, data, or other documentation based on infonnation obtained from a licensee or vendor, which may be ~ discussed or exchanged with those parties and other participants in a study or research program, are not subject to restraint under this policy statement. k. 4. Draft proposed and final rules, policy statements, and other documents pertaining to materials regulated by the Agreement States may be sent to the Agreement States for comment and are not subject to restraint under this policy. 5. Nothing in the policy statement shall automatically preclude the release of agency records pursuant'to a fonnal request under the . Freedom of Information Act, c: / r obert D. Martin Regional Administrator Distribution List C q$/ b 'f l /
- ad;a quv ~w
//
l j# *%,,' UNTTED ETATES p NUCLEAR REGULATORY COMMISSION .,e REQl0N lY s t 4 \\ '...
- g PARKWAY CEf#RAL PLAZA BUILDING 811 RYAN Pt.AZA DRIVE. SUITE 1000 e
ARLINGTON. texas 7str 1 Regional Office Policy Guide No. 0208 -- Revision 0 JAN 2 81935 i COMPLETENESS OF 0FFICIAL FILES A.
Purpose:
1. To establish procedures to ensure that official files contain all relevant documents with respect to regional activities. 2. To provide additional assurance that all legitimate requests made to Region IV for official records are responded to fully and efficiently. B. Discussion:
Reference:
Regional Office Policy Guide No. 0203, Rev., Freedom of Information and Privacy Acts 1. For the purposes of Region IV, official files are those files maintained by the Region IV file room. All official records necessary to support Region IV actions will be in the file room thereby facilitating efficient conduct of agency business and efficient response to F eedom of Information Act (FOIA) requests. !i 2. These procedures do not require the staff to maintain or create additional documents. Rather, they are designed to ensure that all relevant documents are placed in the official files and, therefore, are readily accessible to NRC staff members performing official duties. 3. The procedures required by this Guide will provide for complete official files, and will help assure the completeness of responses to FOIA, discovery, or other appropriate and necessary requests for documents. C. Action All regional staff should become familiar with, and adhere to, the following procedures: 1. Drafts - Once a final document is issued, employees should review the drafts in their possession to determine if there is a reason to keep any of them, suc) as the draft containing substantive information on agency actions not contained in final. If no such reason exists, the draft should promptly be disposed of. If an employee determines that a draft should be kept, the employee shall clearly note on the draft 1 _--a
p U ~ 1 l i the reason for retaining it. The note and the draft shall then be submitted to the file room through the employee's supervisor to assure supervision has knowledge of all substantive issues concerning j the record. .i 1 2. Notes or Memoranda to Files - Notes or memoranda to files are written I for a variety of reasons such as explaining the basis for agency action, preserving a view on a given 4ssue, or to document verbal communications. Whenever an employee writes a note or memorandum to files which contains substantive information about agency action, a copy of the note shall be sent to the file room through his or her supervisor for inclusion in the official files. In all such cases, a copy must also be provided to the employee's supervisor to ensure supervisory knowledge of substantive agency actions. If the employee believes that retention of a note or memorandum is . desirable for more effective or efficient performance and such a note or memorandum does not contain substantive information about agency action, the employee may keep the document as a personal record. ~- However, if the employee wishes to preserve the record as " personal" and does not wish to place the note or memorandum into the official files, he or she must maintain it in a separate personal file located in the employee's office or residence, and not have it typed by NRC personnel other than the employee himself. The note or memorandum g also must not be distributed to, shown, or otherwise shared with other employees. Notes or memoranda handled under these controls will remain the employee's personal property and will not be considered agency records. With respect to personal records as opposed to NRC records, the definition of personal records are those maintained as described above that (1) are not required to be taken by NRC policy or procedures; (2) are prepared for the employee's own use to aid recollection; (3) are retained or discarded solely at the author's discretion; and (4) over which the NRC exercises no control or dominion. This definition is also used for determining agency versus personal records in the context of FOIA requests. 3. Nonrecord Documents - In the case of nonrecord documents not included above, all employees should review these documents to determine the necessity for maintaining the documents. As a matter of sound record management principles, the retention of nonrecord material should be kept to a minimum. Should an employee determine in reviewing nonrecord documents that they are important to understanding agency actions, the document shall be forwarded to the file room for inclusion in the official files. 4 I
i i _, i 4 Working Files - Prior to agency records becoming final and being f. placed in the of ficial files, documents will exist in various stages of development. Employees should maintain such nonfinal documents in a " working file" which is accessible to each employee's secretary and supervisor. This will facilitate locating records when an employee i is absent and will provide for efficient response to FOIA requests by allowing for prompt identification of documents not in the official files. 5. Duplicate copies of official records should not be maintained by individual employees strictly for convenience. Such copies may be l maintained, when necessary, by the Branch secretary or resident 8 inspector s office. 6. During the period from publication of this Guide until the effective date of this Guide, all employees shall review their files to determine if they possess any documents which should be in the official files. As of the effective date of this Guide, FOIA searches will be conducted by searching the official files, which should contain all final documents relevant to agency action, and by j searching the working files of the appropriate employees to identify nonfinal documents. 7. In reviewing all documents, it should be noted that the'FOIA does not require the maintenance of any document prior to receipt of an FOIA g request applicable to the document. Thus, absent other requirements to the contrary, such as specific retention periods required by regulation, an employee may choose to dispose of the document rather than forwarding the document to the file room. The important thing to remember is that employees should not be maintaining agency records in their personal files which are not also in the official files. D.
Contact:
Questions regarding this Guide should be directed to the Regional Counsel. E. Effective Date: i This guide becomes effective 45 days after the date of this Guide. f s o'bert D. Martin Regional Administrator Distribution List: AB
/ %,'t UNITED STATES ,\\ NUCLEAR REGULATORY COMMISSION { / REQlON IV 8 ,E PARKWAY CENTRAL PLAZA BulLOtNG %' ' V *'.....f $11 RYAN PLAZA oRtVE. SulTE 1000 f. (T[ -a ] ARLINGTON, TEXAS 75011 f f -On # MAR 2 51985 J Wi i i 1 Regional Office policy Guide No. 0209. Revision 0 { i ACTION ITEM TRACKING SYSTEM PRDCEDURES A. Puroese: To establish uniform procedures for handling Action Item correspondence through the Action Item Tracking System (AITS). B. Discussion: An important programmatic funct' on of the Regional Offices is to review i and comment on documents originating internally as well as in other Regions or Headquarters Offices. This type of correspondence normally requests that comments / concurrence be submitted by a specific date. C. Action: 1. Processing of Action Items ,s y Correspondence requiring action that is addressed to the Regional Administrator or other staff members will be sent to the Director, Division of Resource Management and Administration (D/DRMA) by the cognizant secretary. The secretary may choose to copy the addressee before forwarding the document to the D/DRMA. The D/DRMA, in consul-tation with the Deputy Regional Administrator, will determine the " Principal Assignee" (usually a Division or other staff office), "Information Copy Recipients," and "Due Date" as shown on the Action Item Control Fom (attached). The correspondence will then be forwarded to the Action Item Coordinator for appropriate distribution i and entry into the AITS. The DRMA secretary will provide backup to the Action Item Coordinator and will be responsible for the AITS in her absence. 1 2. Assionee Responsibilities i a. The person within the appropriate Division / staff office who is assigned the responsibility for coordinating and preparing the i final response document will normally distribute copies of the document to selected staff members for review and comment by the " Input Due Date" listed on the attachment. Often, this must be l i
4
== Regional Office Policy Guide No. 0209, Revision 0 MAR 2 51985 ) accomplished in a short time. Greater efficiency can be developed if the comments are written so that they are useable with only minimal editing or restructuring. b. Following receipt of comments, the person assigned responsibility for coordination must review, edit,'and assemble the comments into a single response document for the signature of the Regional 3 Administrator or his designee. If, for good reason, the "Due i Date" needs to be adjusted, the Action Item Coordinator should be contacted so that a " Corrected Due Date" can be entered into the AITS. 3. Closecut of Action Items When the response is. prepared in. final, the concurrence page a. should include only staff members who had substantive comments ( incorporated into the Regional response document. The Action ) Item number should also be reflected on this page. b. After signature by the Regional Administrator or his designee, the completed package will be dated and the "Date Action -Completed" line on the attachment filled out. The RIV Official File Copy will be attached to the Action Item Control Form and then forwarded to the Action Item Coordinator for closeout. c. If an Action Item is handled in another manner, such as via a telephone conversation, this action should be clearly indicated in the " Remarks and Closeout" section on the bottom of the attachment and then forwarded to the Action Item Coordinator for closecut. l 4. Outstanding Action Items ' On a weekly basis, the Action Item Coordinator will print a composite list of all outstanding action items for distribution to principal j staff members. In addition, a compilation of all closed Action Items d will be distributed on a quarterly basis. i D.
Contact:
Any questions or comments concerning this Policy Guide should be directed j to the Director, Division of Resource Management and Administration (ext. 273). l
k .' Regional' Office Policy Guide No. 0209, Revision 0; MAR 2 51985 E. Effective Date: This Policy Guide is effective upon iss ce. ~ ./ h Robert D. Martin Regional Administrator.
Attachment:
' Action Item Control Form . Distribution List C I' i 'S e en e t' l
I-1 j 1 ) NAR 2 51985' ATTACHMENT REGION IV DATE:' ACTION ITEM NO. I
SUBJECT:
PRINCIPAL ASSIGNEE: p' INFORMATION COPY TO: l l DIVISION / BRANCH COPY ASSIGNMENT: INPUT DUE DATE: l l l l' '1 DUE DATE: CORRECTED OUE DATE: DATE ACTION COMPLETED: REMARKS AND CLOSE0VT:
4' ~ orm NRC-1 (RIV-1/82) I U. S. NUCLEAR REGULATORY COMMISSION REGION IV TRANSMITTAL SHEE~ FOR POLICY GUIDE AND/OR NOTICE l 1 l 0210- POLICY ON THE DISTRIBUTION OF DRAFT INSPECTION AND INVESTIGATION REPORTS l TRANSMITTED: SUPERSEDED: Policy Guice No. 0210 Rev. Policy Guide No. N/A Series Notice No. Rev. Dated: I21 Nc. of Pages 4 i Distribution: B (A-Acministra:1ve 5:sff: B-Professional; AS-All E=cioyees) REMARKS: The enclosure shall govern the distribution of draft inspection and investigation reports. ( 1 Precared by: Pau S. Check Acoroved by: Paul S. Check iS1gnature; tsignature) Ti-le: Deouty Regional Administrator
Title:
Deouty Regional Administrator Oa:e accrosed: October 20, 1983 ' ' ' ' '}}