ML20238A782
| ML20238A782 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/03/1987 |
| From: | Bell W, Cobb L, Davis A NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20237K807 | List:
|
| References | |
| NUDOCS 8708210082 | |
| Download: ML20238A782 (161) | |
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.h REPORT BY THE 766 TASK GROUP TO THE COMAFCHE PEAK REPORT REVIEW GPOUP DATED:
March 3, 1987 8708210082 870312 PDR ADOCK 05000445 O
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UNITED STATES NUCLEAR REGULATORY COMMISSION COMANCPE PEAK REPORT REVIEW GROUP 766 TASK GROUP
' Task Group Members:
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"I/Y S h j-Will 0. Bell Date i
Senior Computer Systems Analyst Data Administration Branch Division of Computer & Telecornunications Services, IRM 3h Q
Leonard I Cobb Da te Senior Program Coordinator Division of Inspection Programs, IE q
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Arthur Davis
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Computer Systere Analyr.t Information Systers Branch Division of Corpu'.er & Telecommunications Services, IRM
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b u~l\\ b u shlo David J. Diehl,4)ctihg Chiaf Date Computer and Tel/ phone Operaticns Branch Division of Information Support Services, IRM
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- Isaac A. Kirk, Director '
Ctte IRM Program Managenert Staff l
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Robert Pierson, Irspection Specielist Dete Opertting Reactors Pro.19 cts Branch Division of Inspection Prograns, IE Task Group Leader:
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. (Lbh 31 8) h Di@ ara A. HartfielW. Tertir?1 Advisor
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TABLE OF CONTENTS I
EXECUTIVE
SUMMARY
II TASK REQUEST AND METHODOLOGY III OIA REPORT
SUMMARY
ON 766 SYSTEM IV PURPOSE, DESCRIPTION, AND HISTORY OF 766 SYSTEM V
CURRENT 766 SYSTEfi PROCEDURES AND PRACTICES VI GEllERAL.0 OBSERVATIONS Af4D PERCEPTIONS VII FINDINGS VIII RECOMMENDATI0t:S IX APPENDICES i
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EXECUTIVE
SUMMARY
Introduction This task group was charged to look at the NRC 766 Inspection Statistical Data System, its purposes and uses, and to make appropriate recommendations to assist the Comanche Peak Report Review Group in its task.
DIA Report 86-10 and its attachments relevant to the 766 system were reviewed. NRC personnel in Headquarters and Regions I and III were interviewed and 766 documentation, correspondence, reports, analyses, and supportinr information were collected and reviewed. Many of the observations about the 766 system covered in Section VI of this report are subjective in nature.
People interviewed had perceptions and opinions about the system and shared them with the group. Phile there were some variations in terms of attitude and perceptions, most people who were interviewed expoused the seme general view. The task group also came to the same general conclusions. Had more time been available, the task group might have been able to be more quantitative when discussing the accuracy of data in the 766 system. The changes over the years in the inspection program, management and management philosophy, and individual Inspectors, among other variables, make a quantitative assessment quite difficult.
In the light of the shift in emphasis from plants under construction to plants in operation and considering the imminent NRC reorganization, it is not clear that the considerable effort required to retrospectively check past data would be productive. Accordingly, the task group l
concentrated on speaking to purposes and uses that the current system can support, with recommendations for future consideration.
Purpose, Objectives, and Uses The original purpose of the 766 system as stated in a 1976 issue of IE Manual Chapter 0535 was to be "a management tool used to capture, maintain, and report statistical and planning data concerning inspection, investigation, inquiry activities, and associated enforcement actions conducted by IE."
Interviews with cognizant NRC personnel familiar with the 766 systen development indicated the principal uses originally envisioned were for budgeting and resource allocation; to monitor Regional performance and to provide field data on the time required to perform inspection procedures in the then new module system. These uses were primarily for Headquarters rather than the Regions.
The objectives listed in MC 0535 were to record in one place: a) number and types of inspections, b) number and nature of inspection findings, c) actiors taken and by whom, d) numbers and type of modules inspected, and e) related statistics and elapsed tine statistics.
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1 1-2 Observations, Perceptions, and Findinos The task group has concluded that in the main the 766 system still meets mest of its original purposes and objectives.
It is being used to help assess Regional performance in the areas of elapsed time to issue inspection reports and to add perspective on escalated enforcement actions as well as other uses involving overall trends and patterns.
It is believed that these are still valid uses for the existing 766 system. The 766 system was not designed to be a significant input to substantive safety decisions and it is not used as such.
While the 766 system meets most of its original purposes it is outmoded and does not really meet the current needs of either IE Headquarters or the Regional Offices.
It is perceived by the Regions to be a Headquarters system and an administrative burden, with limited use to the Regions. The system it not timely or accurate enough to suit most planning needs. The inspection program has changed a great deal since the 766 system was last modified and further changes to the system are badly needed.
The system is not relied on by the Region to provide the definitive i
status of the inspection program at a particular facility, although is can provide some input. Different systems, automated and/or manual, are used for that purpose.
Most of the people interviewed indicate that they would expect some words in an inspection report for each module listed in the corresponding 766 i
fo rm. Othe'rs disagreed and indicated that the guidance on content of inspection reports had varied over time.
Training of inspectors in 766 reporting procedures is minimal and this has exacerbated problems with data cuality. The existing 766 system needs revision and increased training will not solve its problems.
Recommendations 1.
Perform an inspection and enforcement program data needs assessment and then develop a modern system to support both Headquarters and Regional programs.
2.
Establish inspection and enforcement data quality assurance policies and precedures as well as a training program to help assure a consistent, reliable, and timely agency data source.
3.
Consider collecting all inspection and enforcement staff resource data in the Pegulatory Information Tracking System (RITS). Evaluate the benefits of collecting inspection information by SALP functional area rather than by inspection module.
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l II. TASK REQUEST AND METHODOLOGY The letters establishing the Comanche Peak Report Review Group (CPRRG) contained the requirement that:
"The Group should review the purpose and significance of NRC Form j
766 and make any appropriate recommendations concerning its use."
The Chairman of-the CPPRG requested the Acting Director, Office of Information Resources Management (IRM) to assist in performing the review.
Work was begun based on a verbal request which was formalized in a letter from G. Arlotto, Chairman, CPPRG to William G. Mcdonald, Acting Director, l
IRM, dated February 12, 1987. (Appendix 1)
A 766 System Review Group was formed by Mr. Mcdonald including five people from IRM and two from IE, as follows:
Richard H3rtfield, Group Leader, IRM Will Bell, IRM Leonard Cobb, IE Art Davis, IRM i
David Diehl, IRM Isaac Kirk, IRM Robert Pierson, IE Several of the people assigned had working experience in developing, designing,'and operating the 766 systen during various parts of its lifetime. One member had prepared the 1982 version of the 766 IE Manual.
One member had utilized the 766 forms as a resident inspector and another participated in an extensive review of the 766 system, culminating in a task force report in December 1984 (Appendix 2)
Group efforts began with the review of OIA Report 86-10 and its attachments pertaining to or including comments en the 766 system.
Appropriate sections of the IE Manual were obtained and reviewed.
Discussions were held with Headquarters personnel from OIA, IE, and DEDROGR. Three man teams were sent to Regions I and III, eouipped with a comprehensive questionnaire, and held discussions with a broad spectrum of
" Regional personnel, including Division Directors, Branch Chiefs, Section hiefs, individual inspectors, and resident inspectors. Copies of actual inspection reports with the accompanying 766 forms and other documentation and correspondence were obtained. Various computer printouts from the 766 system were obtained.
The group then reviewed the collected information and formulated its report to the CPRRG.
The CPRRG was briefed on February 18 and a draft copy of the task group report was made aveilable for review and comment.
Comments on the draf t were received on February 24 and the report was then finalized.
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o III. OIA REPORT
SUMMARY
ON 766 SYSTEM The basic allegation made by a Region IV inspector was that the data documented in Region IV's HRC Form 766 Inspector's Report was inaccurate.
In addition:
"01A interviewed a number of Region IV managers and inspectors concerning the accuracy of the information i
recorded in the NRC Form 766 systen. The general consensus of those interviewed was that because of carelessness, lack i
of knowledge about the 766 system, and lack of quality control over information entered into the system, the information entered into the system, the information in the automated inspection and enforcement statistical data system was inaccurate.
It was generally believed that little reliability could be placed on any information obtained from the system. However, there was no indication that inaccurate data was intentionally recorded and put into the system in an effort to make the Region IV inspection progren at CPSES look better.
j It appeared to OIA that Region IV personnel were uncertain about the proper method for ccmpleting the NRC Forms 766 and whether there should be a direct correlation between a reference in an inspection report and an entry on the 766
'orm.
There was also confusion concerning how to determine the percentage of completion of an inspection module. These questions centered around whether percent of completion should be viewed as a percentage of the inspection modules ccmpleted or as a percentage of the inspected work activity that was completed at the construction site. Frequent changes.in the implementation cf the 766 system over the years has also created confusion. Additionally, several individuals stated that certain information was recycled on the NRC Forms 766 merely to get the computer to accept the data."
A consultant to CIA reviewed the accuracy of tne NRC Forms 766 that were highlighted in the documentation provided to 01A. Based on his review of a number of NRC Forms 766 for CPSES, he determined the 766 data for CPSES was unreliable. He noted discrepancies between the information on the NRC Forms 766 and the information documented in the ascociated inspection reports. He concluded that some of the NRC Forms 766. data for CPSES overestimated the extent of completion of the Region IV irspection program. His comments are doeurented in Attachment PP cf OIA Report 86-10.
OIA then concluded that:
" Based on the information develooed during this investigation, the data recorded in the NRC Forms 766 pertaining to CPSES is inaccurate and unreliable. The incorrect reporting ranged from
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i III-2 inspection activity recorded on the itRC Forms 766 for which there is no documentation in associated inspection reports to listing inspection rnedules as 100 percent complete on. the forms without completing the recommended inspection activity, merely to clbse the module. ~he cause of the discrepancies appears to be a lack of understanding on the part of.NRC inspectors as to the proper method of, completing the liRC Forms 766."
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s IV. PURPOSE, DESCRIPTION, AND HISTORY OF 766 SYSTEM
. PURPOSE The purpose of the 766 computer-based information system as originally stated in the Inspection and Enforcement Manual Chapter 0535-01 was "to improve organizational effectiveness and efficiency in the areas of collection, processing, retrieval, analysis and management of inspection related data"; the data being a combination of statistical, planning and textual information that is recorded on Forms NRC 766 and NRC 7665/Sc3' Appendix 3).
It was further stated that "The 766 system is a management tool used to capture, maintain and report statir'ical and planning data concerning inspection, investigation, inquiry activities and associated enforcement actions conducted by IE."
The objectives listed were for the system to record in one place:
- 1) the number and types of inspections and investigations; 2) the number and nature of inspection findings with associated text of i
noncompliance item and deviation; 3) the action taken and by whom;
- 4) the nun.bers and types of modules inspected and related statistics; and 5) elapsed time statistics.
DESCRIPTION The system was designed to record on e two part form, pertinent management-oriented information for each inspection, investigation and inquiry. On the 766 part of the form, one finds the type and dates of the inspection and investigation, the number and type of modules (inspection procedures) utilized and related module statistics, such as hours spent, percent complete, etc. On the 766S (currently the 766A)ihrt of the form, one finds the inspection findings with associated textual information on the violations or deviations found l
and the actions taken.
.I The objective of the system was to minimize record keeping for i
inspection-related data and to provide centralized access to inspection data.
From talking to personnel who were working in this area in the mid 1970s, the task group has concluded that the original intent was primarily for IE Headquarters to use the collected data in budgeting and resource allocation and to monitor Regional performance.
For example, since the module system was new, IE planners needed to know how much time, on the average, was being 3
used for each module. The impact of adding a new module could then be estimateo by utilizing data on a comparable module. One could also look for gross differences in time spent on any particular module or on atl modules by different Regions and could fnrmulate questions to help understand those differences.
The timing and flow of the 766 process as original;j plsened is essential to the understanding of the current situation regard ~Ing the utilization of the 766 system. The completed 766 Tonns are entered into the 766 system only after the insrection report has I
been completed and approved by management. This was because the inspection findinrs (contained on the 7665 fctm) could change A
IV-2 during the inspection report review and concurrence process. This total process is currently supposed to take approximately one month but at times cculd take considerably longer depending en type of inspection and the enforcement findings. The routine data associated with the module apparently is modified far less frequently than the findings.
The December 1984 task force report (Appendix 2) recommended that to improve timeliness the module data be entered within a few days of the inspection with the data on findings to follow report issuance.
This recommendation was not implemented.
The system was used by IE to record basic statistical data concerning each inspection, investigation or inquiry, related module tracking information, noncompliance statistics and the text related to each iten, of noncompliance, whether cited or not, and deviations. The data was used as input into the 766 statistical data file, the Module Tracking System to update the inspection scheduling and planning networks, and the Enforcement Text System which provided monthly input into various management information systems and reports. The 766 system was to serve as the primary source of all statistical information relating to inspections, investigations, inquiries and enforcement. The data frem the system was to be used to " analyze various aspects of the inspection programs; answer inquiries from Congress, the Conmission and other sources; provide part of the basis for budget requests; help in the analysis of enforcement cases; and provide requested data to licensees and contractors regarding the compliarce records of licensees." The 766 system was also designed in anticipation of assessing inspection fees. This feature of the 766 system was never utilized.
HISTORY During the early and mid 1970's AEC/NRC operated under a centralized management philosophy which was reflected in the design and development of management information systems that the regions were tc use in support of headquarters needs and requirements.
In the mid 1970's a system to collect basic statistical data about i
each inspection such as the docket number, the type and dates of the inspection, the person (s) conducting the inspection, and the results of the inspection (clear, violations, deviations, etc.) was expanded to include the module data and associated enforcement action information. This was called the 766 system. The original system was a combination of computer programs written under various software languages using multiple fata files that had to be merged in order to generate comprehensive reports.
During the early 1980's the 766 systen: wn redesigned to utilize a more up-to-date technology, that of a data base managenent system (DBMS). Accordingly, the 766 systen was rewritten under the SYSTEM 2000 (52K) DBMS to allow a more efficient methodology to update and access the 766 data. The Ferms NRC 766 and NRC 766A (Appendix 4) were also redesigned with the input and
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IV-3 concurrence of the Regions to minimize the administrative paperwork required by the Inspectors. A number of data elements that were no longer needed were eliminated and the form was changed to allow multiple inspections to be reported cn a single form.
By the early 1980's, the management approach had changed to one of decentralization (regionalization) which gave* considerably more power and authority to the Regions for the management of their programs. With IE Headquarters having decreased authority and support and with the increased availability of microcomputers in the Regions, the usefulness of the 766 system data for Regional planning became eroded. The 766 system was st'ill perceived as a Headquarters system and one that has became less and less relied on by the Regions for information. During this time the inspection program also changed. The Systematic Assessment of Licensee Performance (SALP) program was developed, which looked at functional areas which did not necessarily correspond to specific inspection modules. Various degrees of inspection programs were developed (minimum, basic, and supplemental), to be used, depending on such things as SALP ratings..The 766 system has not been modified to account for these latest program changes.
The cc:t for the 766 system for FY-1986 is estimated to have been
$260,000, which includes NRC personnel costs (5 FTE), contractual, and computer costs.
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CURRENT 766 SYSTEM PROCEDURES AND PRACTICES PROCEDURES l
l Two IE Manual Chapters 0535 and 0537 are currently in effect with the general purpose that each Regional Office and Headquarters maintain a high degree of accuracy in the collection and processing of inspection, investigation, and enforcement data into the 766 database.
Manual Chapter 0535, Statistical Data Reporting (766 Computer System)
(Appendix 5) provides the instructions for the completion and handling of the NRC Forms 766 and 766A for various statistical, planning, and textual data concerning inspection, investigation, inquiry, and associated enforcement actions. The instruction also discusses the responsibilities of the appropriate persons for filling out the forms.
Manual Chapter 0537, Quality Assurance Program for the 766 Computer System (Appendix 6) outlines the various steps to be taken in conducting i
a quality essurance program on the 766 deta after it has been entered into I
the system.
It should be noted that this Chapter was written in 1979 and was not updated when Manual Chapter 0535 was revised in 1982.
PRACTICES In practice, one finds that the Regions differ in approach and degree of implementation of the IE Manual Chapters. One Region had its own version of MC 0535. Both Region I and Region III conducts or had data entry contractors check that the reported 766 data agrees with that actually entered into the 766 system.
They also checked for data completeness and contacted inspectors when they uncovered problems of omission.
Regional supervision indicated that they checked for the " reasonableness" of the 766 data included with the inspection report.
Trainino to inspectors en how to fill out the 766 forms appeared to be primarily on-the-job training with lead inspectors or supervision.
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l VI. GENERAL OBSERVATIONS AND PERCEPTIONS CURRENT USE OF THE 766 SiSTEM 1.
By Recional Offices Data from the 766 System is used by Region III to assist in the management of the reactor inspection program. However, there is a considerable amount of information outside of the data in the 766 system that the Pegion needs to manage the inspection program, such as unresolved matters from previous inspections that require additional inspection effort; incidents, IE information notices and bulletins; and requests from NRR that need followup inspection.
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inspectors maintain records of the inspecticn work that has been accomplished as measured against the inspection plan for the plant.
They develop inspection schedules based on their records of the status of the inspection program (some of the data comes from the 766 system); the computerized outstanding items list for the plant; SALP ratings for individual functional areas; and other plant specific data.
Region I uses little data from the 766 system in the management of the reactor inspection program. Senior resident inspectors maintain records of what inspection work has been accomplished and what still needs to be done. Region I uses the outstanding items list and other plant specific data in the same manner as Region III. But Region I does not normally extract data from the 766 system to assist in the planning and scheduling of inspections.
With the exception cf limited use of the 766 data in the regional systen for tracking inspection work, inspectors generally do not use data frcm the 766 system. They view the 766 system as being primarily for the benefit of Headquarters management.
Management in the two regions has made limited use of 766 data as an oversight tool for determining whether specific types of inspections have been perforr:ed at a plant and for estimating inspection work that needs to be completed to satisfy the requirements of the IE Manual.
This overview takes into account the fact that the data may be two to three months old at the time they see it, and that it may not be completely accurate. However, it is sufficiently current and reliable for a gr iss check of regional inspection activity.
The Regions have developed their own systens for managing the reactor inspection program because the 766 data was not timely and did not contain many types of information needed to plan and schedule regional inspections. The 766 system was designed to record the history of individual inspections. It was not dasigned to be a scheduling tool.
As a consequence, there are certain types of data that are not included in the 766 system, but which are vital to the planning and scheduling of inspections. Sc regional offices have developed other systems to meet that need.
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s VI-2 Data is put into the 766 system after the inspection report and accompanying letter to the licensee has been issued. The reason for that requirement was to ensure that the record in the computer reflected the record in the inspection report and letter to the licensee. While that step helps to ensure that violations in the 766 record are the same as those actually cited to the licensee, the delay makes the data less valuable for planning and scheduling inspection work. Recently IE previded a summary of data to the regions which showed a country-wide average delay of about two months from the last date of an inspection until the date that the inspection is recorded in the 766 system. Part of that delay involves a delay in providing input forms to the regional computer staff and in further delay when other work assigned to that staff has a higher priority.
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By Headquarters The Enforcement Staff routinely uses the record of violations in the 766 system for a particular licensee to add perspective to a decision about what level of escalated enforcement actior. to take against that licensee.
The inspection procedure data are used to a limited extent by IE in the assessment of regional performance. For example, to determine rcughly whether the routine program of inspection has been completed ind to monitor expenditure of inspection time versus SALP ratings. An example of 3his latter use is a memorandum dated Jar.uary 2,1987 from the Director, Division of Inspecticn Programs, IE, to each project Division Director in the NRC regional offices. (Appendix 7)
The average time to issue inspection reports periodically is tabulated and provided to the regions. Those offices who are not neeting the standard for issuing reports are requested to take corrective action to neet the standard. An example of that use of the 766 data is the memorandum issued by the Director, Division of Inspection, IE, to the Deputy Regional Administrators, dated December 31,
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(Appendix 8) j Regarding delays in getting 766 data into the computer, IE, hes brought this subject to regional attentien from time to time. An example of that usage is the remorandum dated December 19, 1986 frem the Director. Program Support and Analysis Staff, IE to the Directors, Division cf Resource Management and Administration in the regional offices. (Appendix 9)
PROBLEMS WITH THE 766 SYSTEM There is a belief among many of the Regional staff who were l
interviewed that the 766 data is unreliable. They point ir particular to the data about time expenditure, percent completion of individual inspections procedures, and the difficulty o' determining, at times,
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to which procedure inspection time should be charged. However, the feeling about the poor quality of the data in the 766 system includes more than the three data fields just identified This general feeling about the inaccuracy of the data apparently has discouraged some regional staff members from trying to use it. Others have tried, but having encountered a problem, have decided to devise their own system of duplicate data collection.
For example, to record manually certain data from the 766 input form such as tine charged against each inspection procedure. During interviews in Regions I and III no specific examples were produced which clearly demonstrated the "unreliability" of the data.
On the other hand, specific efforts were identified in Regions I and III to ensure a reasonable level of data quality in the 766 system.
Section Chiefs stated that they give a " reasonableness check" to the data input form that is part of the package which the section chief approves in connection with approval of an inspection report. The computer staff.in each of the two Regions described the edits they perform when they receive the 766 system input forms from the I
inspection staff. These quality checks involve examining the form to determine whether there is missing data. However, it was also reported that personnel worked around the system if data was rejected because of invalid modules, etc.
The 766 system automatically edits the data as it it being entered into the computer and rejects records that do not meet the criteria built into the computer audit. The computer staff returns these re.4ected forms to the inspections staff for correction and, in general, reports reesonable cooperation ir correcting the errors and L
returning the forms to the computer staff. As a further indication of ouality of the data in the computer, both reginns reported that the same individuals have been entering the data for a number of years, are faniliar with the data and the. system, and review the data in the computer against the input forms in an effort to ensure accurate transfer of information into the computer.
The following sections discuss specific problems with the existing 766 systen:
1.
Timeliness of the Data On the averace the data about an inspection is about two months old before it is entered into the system. This is partly due to manage-rent direction that there be no data entry until the inspection report is approved and issued -- and partly due to delays in gettird the necessary input form to the A0p staff for prccessing. A further problem is that updating the system has received a low priority as compared to other source data collection work such as the Regulatory Information Trccking Systen (RITS). The prio;ity assigned to processing data appears to be related to the Region's perception of 1
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VI-4 Headquarters' interest in the system.
Region I stated that RITS has received more attention than the 766 system because it is the basic system for controlling allocation and use of human resources, a subject in which both Headquarters and the Regions have great interest.
An illustration of Regional response to Headquarters interest in the system involves the memorandum of December 19, 1986, previously cited.
The computer staff in Region I described the actions that Region I was taking to improve the timeliness of the data. These actions are summarized in the response from Region I to IE, dated January 29, 1987. (Appendix 10) 2.
Record of Violations The record of violations in the 766 system is not completely accurate because the final decision about violations in an escalated enforcement case may not appear in the 766 system. There is no requirement in the IE procedure for revising the data in the 766 system to reflect those final decisions. Although the foregoing is a fact, the net effect is not large because of the small number of escalated enforcement cases versus the volume of citations that are handled routinely by the regions as a Notice of Violation. However, this lack of updating of the data after escalated enforcement has taken place does mean that the enforcement history of a plant may not be completely accurate as recorded in the 766 system.
3.
Percent Completion of an Irsoection Procedure The individuals interviewed in Regions I end III repeatedly emphasized their belief that the data in the 766 system concerning the percent completion of an inspection precedure was not reliable. They expressed the opinion that these data were unreliable because of the design of the inspection program itself and the design of the 766 systen.
First, there is no defined basis for calculating percent completion.
Is percent completed based on the number of line items within the inspection procedure that are completed, the inspection tine estimated by the inspector to complete the procedure, or cn some other basis? Secondly, the volume of work is not, and prcbably can not be rigcrously defined because of problems encountered at the site and the fact that judgement is a large factor in how much the inspector does to complete the is. tent of the inspection procedure. Thirdly, the 766 i
system design does not allow for summing up completion percentages when more than one inspection by more than one inspector is necessary to complete the work. The system may show only that fracticn of work which was completed during a particular inspection.
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VI-5 Construction inspection procedures generally require more than one inspection to complete; sometimes considerable time passes before the work is completed under the inspection procedure and tae remaining work may be perforned by a different inspector.
Consequer.tly, estimates of percent c.ompletion serve only as indicators of the status of construction.
As an illustration of the little meaning that can be placed on ?.he
" percent completion" data, here are quotations from the current !E Inspection Manual that illustrate the expected varability of work en individual inspection procedures in order to carry out NRC inspection policy. IE Manual Chapter 2512 describes the program for reactors under construction (Light Water Reactor Inspection Progran -
Construction Phase).
In Section 2512-06 the policy is stated that "The arcunt of inspection effort required to ensure the same degree of confidence that construction is adequate will vary from site to site.
Similarly, different types of construction activity at the same site may require various levels of effort to provide the same degree of assurance of quality work. Generally, an increase or decrease of inspection effort will be based on an evaluation of the licensee's performance such as through the SALP program." Similiarly for operating reactors the pertinent IE Manual Chapter is 2515, Light Water Reactor Inspection Program - Operations Phase. Section 2515-09 of that Chapter states that "Although each inspection procedure contains many line items, these items are provided as guidance and the individual inspector is expected to apply a professional judgment regarding the need for completing each specific item."
Section 2515-06 requires that resident inspectors spend about 20% of their time on what is termed " independent inspection effort", i.e.
inspection not required by a routine inspection procedure. That rather large. block of time must be divided between inspection procedures based on the inspector's judgement es to where his/her effort falls. This introduces a significant uncertainty in the consistency with which data about independent inspection effort is recorded and thus a definite unreliability in the time shown for individual inspection procedures.
4 Time Spent on Individual Inspection Procedures The 766 system requires that the time spent making an inspection against each inspection procedure be recorded in the system.
Both inspectors and supervision in the two regions stated that time data for individual irspection procedures prcbably is grossly inaccurate. This is due to a variety of factors including:(1) the inspection work can not be logically recorded against any one inspection precedure, i.e. the work could fit urder either of two I
different procedures; (2) the individual inspector decides against which inspection procedure to show the time; (2) the nature of the activitics at the site frequently do not allow an inspector to i
VI-6 concentrate solely on one inspection procedure until the work is finished -- he/she may work now on one, then another, etc., then back to the first or second --- thus creating time keeping difficulties; and (4) lack of motivation on the part of some inspectors since they rarely see the data after it is recorded on the 766 input form.
NRC currently collects time data from inspectors in three systems: the T&A for payroll; the RITS for budgeting, licensee fees and tracking use of time against budgeted levels; and the 766 system for tracking use of time against specific inspection procedures (modules). Obviously this creates some confusion and an administrative burden on inspectors.
The Regions are focused on accounting for time in terms of SALP functional areas in accordance with IE directives on this subject.
Those directives require that inspection effort at individual plants be related to SALP ratings. Sorre inspection procedures cannot be categorized into just one SALP functional area.
The resident inspector or project inspector divides the time charged to an inspection procedure between the appropriate SALP functional areas. However, the 766 system was not designed to do this.
Consequently, each inspection procedure must be assigned to a particular SALP functional area when data is retrieved from the 766 system and reported by IE as inspection time expended for each functional area. These 766 data do not necessarily agree with the Regional data, thus creating the appearance of unreliable data.
However, the difference is not d.e to unreliable data but on how the data are split between SALP functional areas. For example, Inspection Procedure 71707, Operational Safety Verification, requires a weekly inspection l
of accessible areas in the plant. The scope of these weekly inspections covers all aspects of the plant and potentially can fall into at least these eicht SALP functional areas: plant operations, radiological controls, traintenance surveillance and in-service testing, training, emergency prepar,edness, fire protection and housekeeping, and security ard safeguards. While the region splits the inspector's time between the various SALP functional areas, the 766 time for Inspect'on Procedure 71707 is probably shown completely as the SALP functional area: plant operations.
TRAINING AND MANAGEMENT ATTENTION Most inspectors learn how to complete the 766 form from other inspectors as part of their on-the-job training and/or they are given the written instruction that describes the system. Region I and III staff members said that there is a line item in the orientation
,iournal dealing with computerized data systems. As part of initial qualifications for the inspector position, new employees must complete this item as well as the others in the journal. However, no formal training program exists in the two Regions tc ensure that inspectors i
understood how to complete the 766 forms.
VI-7 Persons interviewed in the two Regions opined that regional management had devoted little attention to the 766 system. As compared to other problems ~ involving. substantive safety issues and other matters of importance to both Regional and Headquarters management, the 766 system has not appeared to merit particular management attention.
Summary Observations on 766 Uses and Data Accuracy In summary, the 766 system can still be used for much of what it' was originally designed for. One can identify numbers of inspection reports, the modules utilized for each inspection, and the total number of hours spent in direct inspection activity for each inspection.
While the hours spent on each module may be somewhat in error because it is scmewhat hard to estimate, that information could be used in a gross sense for overall trends. Data on percent complete is less accurate and less meaningful. Data can be used to establish elapsed time between inspection and report issuance and what inspection findings were made.
It is appropriate-here to briefly summarize what the Reg on and Headquarters do not use the 766 system for. The NRC doeL not utilize the 766. system by itself to make substantive safety decisions. The system may be used to help identify an inspection report at a yarticular facility that could shed some light on a certain subject, but any decision would be based on much riore detailed information.
The 766 was not designed to be a significant input to safety decisions and it is not used as such.
It is also not directly used as input to the letter the Region prepares indicating that a unit has successfully completed construction and is ready to receive an operating license.
The Administrator for Region IV shared his views on this subject in a December 17, 1986 letter to the EDO.
(Appendix 11)
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VII. FINDINGS The 766 system does not appear to be actively and extensively used in support of Headquarters or Regional management. The purpose of the 766 system has changed over the years to the point where most inspectors and some managers are not really aware of its intended purpose and use. The current system is over ten years old. During this time the NRC inspection program has changed and management needs have been redirected to address operating reactors. The system has not kept pace with technology benefits which are currently available within the NRC.
Policies and procedures have not kept pace with 766 system upgrades thus leaving the Regions little option but to establish their own tracking systems. As a consequence each Region reviewed appeared to have developed their own internal tracking system for monitoring inspection requirements independent of the 766 system.
Headquarters cannot monitor Regional performance or a timely basis with the 766 system because the data can be as much as two to three months'old before it is entered into the system.
In effect some of the data when entered is too old to provide an up-to-date database for use in inspection planning and monitoring. The principle reason for this is due to a management decision that there be no data entry until the inspection report is approved and issued.
Headquarters, hcwever, does have a need for seme of the types of information included in the 766 system.
For a number of reasons some of the data are inherently inaccurate and unreliable. There does not appear to be any formal training for inspectors in the use and purpose of the 766 system. Training of new i
inspectors in the use of the 766 system is provided by the new i
inspectors' Supervisors and the consistency and quality of this training varies from good to nonexistent. Because of the relative ignorance of inspectors as to the purpose and function of the 766 system, many inspectors have a low regard for the 766 system and treat their date input tasks as an administrative burden with little regard for the accuracy of the data. Compounding this problem are the intrinsic difficulties in maintaining time accountability against a particular module number due tc the way the inspection procedures in the modules are written and the nature of the activities being inspected. As a result in some cases the hours collected against a particular module represent at most the cumulative best guess estimate of a number of inspectors. Section Chiefs do give a reasonableness check to the data input form but there.is no dedicated effort toward quality centrol such as required periodic aucits of the data against the source documents - inspector reports. The IE Manual contains an instruction which requires the Regions erd Headquarters to make certain cuality checks. However, with the exception
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of occasional menos, there has been no persistent management attention to insisting that the data be accurate. As a result it can be concluded that the present method of attributing a certain number of hours in an inspection effort to a particular module is cumberscee and in many cases of such dubicus quality as to be meaningless. Also contributing to the
VII-2 difficelty of using the 766 system as a reliable and accurate tracking system is. the lack of conformity in defining how to compute percent completion of a module and the inability of the system to add up the percentages of completeness when more than one inspection is made under the same procedure. Redefining and quantifying percent completion with respect to the inspection modules would provide more consistency and Regional conformity but at the expense of inspector flexibility and effectiveness. The net result likely would be counterproductive and the tracking insight gained would not be worth the reduced inspector productivity.
As presently construed and implemented, the 766 system provides a data record that shows that a certain inspector performed an inspection at a plant at a particular time and also indicates which modules the inspector thought he was inspecting at that time.
The findings listed above are in basic agreement with the findings of the December 1984 task force.
(Appendix 2) l l
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VIII.
RECOMMENDATI0flS The following recommendations could be treated as one recommenda-tion. They were separated primarily because recommendations 2 and 3 could be implemented fairly quickly, which would improve the existing 766 system without having to wait for the new system called for in Recommendation 1.
1.
The current state of the 766 system and the pending NRC reorganization reflects a need for a complete inspection needs assessment. The information needed to support management and staff inspection programs appear to exceed the current system's functional capabilities ar.d a system should be developed which facilitates current technology capabilities (i.e., enline access for updating and reporting etc.). An integrated system should be established which supports both Headquarters and Regional
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inspection programs.
2.
Establish enforcement and inspection data quality assurance policies and procedures, and a training program which will assure consistent and reliable information. Accountability for the integrity and reliability of the information should be assigned to the Office / Region with the program function.
3.
Consider consolidating the collection of staff resource data into the Regulatory Information Tracking System (RITS).
Evaluate the benefits of collecting staff resources as they relate to the SALP functional areas as opposed to current 766 procedures which collect resources by inspection module'.
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IX. APPENDICES Appendix 1 - Memorandum from Guy A. Arlotto, Chairman, CPRRG to William G. FcDonald, Actinp Director, IRM dated February 12, 1987, re Comanche Peak Report Review Group Task RG IPM-01 Appendix 2 - Memorandum from 766 System Task Force to J. Nelson Grace, Director, Division of Quality Assurance, Safeguards, and Inspection Programs, IE dated December 13, 1984, re Report of the 766 System Task Force Appendix 3 - NRC IE Manual Chapter 0535, " Statistical Data Reportina (766 Computer System)" dated November 24, 1976 Appendix 4 - NRC Forn 766, Inspector's Report, Office of Inspection ard Enforcement Appendix 5 - NRC IE Manual Chapter 0535, " Statistical Data Reporting (766 Computer System)" dated January 1, 1982 Appendix 6 - NPC IE Manual Chapter 05?7, "Ouality Assurance Program for 766 Computer System" dated December 31, 1979 Appendix 7 - Memorandum from James G. Partlow, Director, DIP:IE to Dennis F. Kirsch, Director, DP.SP:RV dated January 2, 19P.7, re Periodic Report on Regional Implementation of the ?515 Program Appendix 8 - Percranda from James G. Partlow, Director, D!P:IE to Deputy Pegional Administrators dated December 31, 19E6, re Elapsed Time to Issue Reactor Inspection Reports Appendix 9 - Note from James L. Blaha, IE to Distribution List dated December 19, 1986, re Timeliness Statistics from 766 S"stan Apnendix 10 -Memorandum from Anthony T. Gody, Director, DRMA:RI to James L. Blaha, Director, PSAS:!F dated.1anuary 29, 1987, re Tireliness Statistics 'rrn 76C System Appandix 11 -Memorandur #rrn Rcbert D..rr+in, Panional Administrator, Decion IV, tn vic*cr Stallo,.'r., ED0 deted December 17, 1986, re OIA Pacort Deview: 01A File No. 86-10
APPENDIX 1
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j W AENINGTON, D. C. 20555
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FEB 121987 i
MEMORANDUM FOR: William G. Mcdonald, Acting Director Office of Information Resources Management FROM:
Guy A. Arlotto, Chaiman Comanche Peak Report Review Group
SUBJECT:
COMANCHE PEAK REPORT REVIEW GROUP (CPP.RG) TASK RG IRM-01 By a memorandum of January 21, 1987, entitled OTA REPORT REVIEF: OIA FILE
- 86-10-ESTABLISHMENT OF REVIEW GROUP the Executive Director fer Operations assigned to the CPRRG the task of reviewing the purpose and significance of the comnputer-based NRC 766 System and make appropriate recomrrendations concernine its use. A copy of the ED0's memorandum is attached.
In order to assist the CPRRG in the accomplishment of this task, we recuest that you assign appropriate personnel to examine the NRC 766 System purpose Prd use and provide the CpRPG with a report that includes the following:
1.
The intended purpose and use of the 766 System.
2.
Determine if the current use of the 766 System by both Headquarters and Regional Office management is consistent with the intended purpose. Does the existing 766 System meet the stated purpose 7 What reasonabie use can be made of the 766 System?
3.
If the 766 System does not fulfill its intended purpose and if this purpose is necessary for an effective Inspection and Enforcement progren, how are these ob.iectives currently being accomplished?
4.
Alternatives and recommendations for the continuation of the NFC 766 System in order to satisfy the needs of NRC Headquarters and Regional Office managenent.
In perfoming this task, please document this basis for yrur ennclusions er opinions. In develooirs this basis you should, as appropriate, interview members of the IE and Regional Office staffs.
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William G. Mcdonald Your draft report should be submitted to th CFPPG py r bruary 17, 1987.
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(Q Guy. Arlotto, Chaiman Coma che Peak Report Review Group
Attachment:
As stated cc:
C. Heltemes, AEOD C. Paperiello, RIII J. Lieberman, OGC
'J. Goldberg,.0GC R. Erickson, NMSS P. McKee, IE I
S. Collins, RI l
D. Crutchfield, NRR R. Hartfield, IPM 1
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wasMiscrow. o. c.rosos p.civ,e December 13, 1984 MEMORANDUM FOR:
J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs, IE FROM:
766 System Task Force
SUBJECT:
REPORT OF THE 766 SYSTEM TASK FORCE l
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Enclosed is a report of the results of the review that the Task Force completed of the 766 System. As you requested, the review was focused primarily on '
regional offices, their use of the data, the problems they were encountering with the system, and the ways the system could b,e improve,d to make it more useful for the regional offices.
j The task force was made up of the following members:
Steve Ramos, Chairman Edwin Fox George Barber James Konklin Wayne Scott Judy Kronenberg Edouard Trottier Leonard Cobb Steve Ramos, the Chairman, left for the private sector before the Task Force had prepared a formal report of its efforts.
In a subsequent meeting, the Task Force designated me as the one to prepare the report. A draft report was trans-mitted to each Task Force member for review and their comments were incorporated into the final report. Thus, the report represents a consensus view of what needs to be done to improve the 766 system. On one point, however, involving timekeeping, there is a minority view and that view is clearly pointed out in the text of the report.
.f 3
eonard Cobb, Secretary 766 System Task Force cc:
J. Taylor, IE E. Jordan, IE J. Partlow, IE B. Grimes, IE J. Blaha, IE E. Greher, IE Task Force Members
s December 11, 1984 REPORT OF THE TASK FORCE IMPROVEMENTS IN THE 766 DATA PROCESSING SYSTEM DIVISION OF QUALITY ASSURANCE, SAFEGUERDS, AND INSPECTION PROGRAMS OFFICE'0F IN3PECTION AND ENFORCEMENT SCOPE The Director, Division of Quality Assurance, Safeguards, and Inspection Programs, IE, established a task force to recommend whether the so-called 766 system should be terminated, combined with another system or improvements made in the existing system. The facts that were developed during intensive interviews with regional' inspectors, supervisors, and managers were the primarly basis for the
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evaluation of the system and subsequent recommendations.
METHODOLOGY Sub groups from the Task Force visited each region and held intensive interviews with resident inspectors, regional inspectors, first-line supervisors and various.
higher levels of regional management including the regional administrator, when available. The purposes of these interviews were to determine how the data from-the 765 system was being used in each region, to identify problems encountered in attempting to use the system and to solicit recommendations for system improve-ment. After interviews with regional staff were completed, a subgroup from the Task Force met with representatives from all regions to discuss ideas for improve-ments in the system including concepts for development of a new and improved system.
FINDINGS AND ANALYSIS Uses of the System In regions where tne capability exists to retrieve cata from the system, the principal use is to develop data about inspection findings as part of the SC.P evaluations. There is also limited use by the enforcement staff and by some of
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. the technical inspection sections, especially those where the section makes inspections at an annual or semi-annual frequency and can tolerate the delay in updating the status of inspection information in the system. However, the vast majority of inspectors derive no benefit from the system and track performance of required inspections by a variety of manual means. In addition, each region has a computerized system for tracking " outstanding" items. These include non-compliance items, reported incidents, unresolved matters that were discussed with licensee management, planned repairs of defective / failed equipment, etc.
When the data in the 7.66 system is used by a region, there also exists an appropriate managevent climate and ADP capability for prompt retrieval of the data. By appropriate climate, we mean that the regional management supports and encourages the use of the data. Management also provides an adequate auto-mated data processing staff so that requests for reports can be handled in no more than a couple of days. Regions II and III were examples of an appropriate i
management climate and an adequate ADP capability. Region I had no retrieval 7--
3 capability. Region IV and V had the necessary ADP capability but the super-s visors who were interviewed indicated that the 766 system was moie of a problem than a help in getting their work completed.
- All regions would use an automated data system to track inspection completion and to aid in planning future inspections if the data could be entered into the system promptly after each inspection. The Regional Administrator, Region III, has formally requested the Director, Office of Resource Management to develop such a system; however, no work has been undertaken on his request. The E yional Administrator, RII, has proposed that the development of such a tracking /
planning system be considered as a program improvement, initiative in response to i
the October 22, 1984, request from the Director, IE. No formal decision has been made regarding those program impovement initiatives. They are being considered 1
for inclusion in the next budget request.
Although the focus of the Task Force was on regional uses, we note that there is considerable use of the 766 system by the IE staff. These uses in:1ude development of background information by the PAT and CAT teams on reacters teey plan to inspect, monitoring by SMPB of the status of the regional fuel fa:ilities and materials inspection program, assistance in determining relative complian:e
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3 records between licensees who have received civil penalties and a licensee for whom one is being considered, evaluation of program areas to determine where I
more or less emphasis should be placed, and as input to the " white book" published by the Vender Branch.
Timeliness The current system is designed so that no data can be entered into it until the l
inspection report is issued to the licensee. That requirement was put into the system to ensure that recorded noncompliance items are the same as appear in the notification to the licensee as to the results of an inspection. The inspec-
-tor's preliminary findings are reviewed by supervision and are subject to change in either direction. As a consequence, there is an appreciable delay before the data can be' entered into the system.
In addition, a further significant delay. occurs in some regions because of the j
-low priority that is given to updating tre 766 system as compared to systems the region generates for internal use and the need to' update the RIT5 system. (RITS l
is a staff hours accounting system with a considerably higher amount of detail than the one it replaced, the so-called MPS system that had been used to account for use of regional staff time.)
As oreviously stated, the regions have a need for an automated system for track-ing inspection procedure completion. The 766 system could be used in place of the many manual systems for keeping track of the status of the inspection program.
q From the data in the 766 system the inspections that need to be performed during the next quarter of the year could be derived. Tne resulting inspection scheduled l
would require modification due to SALP results, plant status, and other consider-ations.
i If the noncompliance data could be detached from the 766 system, the other data could be inpatted into the system within a few days of the return of tne inspector to the office. None of the otber details in the system require a revie./ cr l
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. judgment on the part of the supervisor. They are matters of fact: who was inspected, when, what procedures were used, per cent completed, time applied against each procedure, etc.
Accuracy of the Data 1
i Accuracy of the data in the system is a continuing problem. Although we have not done an audit of the data, we gained the impression from our interviews that accuracy is a function of supervisory interest and regional use of the data.
When the only activity is inputting of the data for someone in headquarters to use, the accuracy appears to suffer. ADP staffers told us that the rejecting rate for data on forms that inspectors fill out averages 24%. Rejection is based on a review by the ADP person to determine that all blanks on the form are com-plated and that in general, there are no obvious errors. If the form passes that visual test, the data is inputted into the computer and checked against a computer edit.
For example, the computer checks a docket number against a list of docket numbers to deterinine that the number is a valid docket. It can't tell, however, whether a wrong docket was put into the computer. Based on thesh visual and comDuter checks, the ADP person returns to the inspector any forms that she/he can not correct. The problem is that frequently it takes many weeks before the form is returned to the ADP staff for final inputting into the 766 system.
Some regions, or parts of regional staffs, have instituted their own quality checks. For instance, during the assessment of the regional materials inspection program in 1984, two regions described a required review of data entered into the computer against the records of the inspection.
This quality check was done by the originating inspectors. Also, in all regions, the 766 input form is part of the package that the Section Chief reviews when the inspection report is sub-mitted by the inspector for signature.
In contrast to the relatively undisciplined or nonexisting quality control program in some of the regions, the NRC Document l
Control System has a 100% audit of all entries into the computer by an independent staff to ensure essentially error free data. Given that the 766 system is an official agency record, similar effort by the regions seems warranted for assuring the cccuracy of the 766 data.
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14 5-Time Reportina Under the 766 System For many years there have been two systems accounting for the inspecton time of inspectors. The first is the MPS or RITS system that accounts for all time and the second is the 766 system that accounts for only time spent on direct inspection activities. Recently the complexity of having to maintain two sets of records has been increased because of the increased detail involved with the RITS system, the region - sponsored replacement for the IE-sponsored MPS system.
The mere fact that the inspector has to divide his/her time in two different ways is sufficient to introduce a significant element of inaccuracy in the data.
However, for the 766 system an even more important factor is the manner in which many inspections at reactors are conducted as compared to the way the inspection program is constructed. As reported by essentially all inspectors we inter-viewed, they frequently are working on a number of inspection modules at the same time. That is, they do some work on one, move to another, perhaps get involved in a third, than follow up latter in the week with the second, etc.
Thus, at the end of a week in the majority of cases, and even at' the end of a day in a few cases where inspectors are particularly conscientious in their time keeping, the possibility of reasonably accurate accounting of time is not high.
Unless we want inspectors to spend an inordinate amount of time checking their watches and writing down times, instead of focusing on the inspection itself, it is unlikely that we will have truly accurate records of how time was spent to perform particular inspection procedures.
Another factor that was stressed by a number of inspectors was the fact that in a significant number of cases it is not absolutely clear against what inspection procedure they should record their time. A frequently cited example was the case of inspecting to find out the nature and cause of a licensee event and later to followup on licensee corrected actions. These inspections involve items that could be charged either to a routine or an "as needed" inspection procedure. The most commonly cited problem related to the independent inspection module. With the increased regional attention to ensure a high fraction of time charged to independent inspection, the tendency is to emphasize the independence of the inspection effort rather than attribute it to other inspection procecures.
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. Individual inspectors had subjective estimates of the error involved in the time charged to individual modules based on the above analysis and other factors. These estimates varied from about 20% to about 100% error in the times recorded in the 766 system.
Another problem with the timekeeping data in the 766 system is the fact that there is no computer edit of the timekeeping data. A typical computer edit would ensure that the total time recorded for an inspection would not exceed the total time the inspector was on-site, or on-site plus off-site time spent inspecting licensee documents. Thus, even though the times charged to individual inspection procedures might not be accurate, the edit would at least detect overall errors in the inputting of the data. Now 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> can be inputted as 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, or 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> (and an infinity of other possibilities) and the system will not. reject the erroneous data. By contrast the MPS and RITS staff' time accounting systems edit total time against time charged in the payroll system for that individual.
Timekeeping has been a part of the 766 system since its inception in the early 1970s. Despite 10 years or so of data, it is hard to find examples of where any use has been made of that data. All known attempts to use the data have ended up in frustration and failure due to two factors:
The wide variation in times that were charged to an inspection procedure a.
with no statistically meaningful pattern to the data, b.
Although one would think that the direct inspection time for a particular plant in the 766 system should be reasonably close to the direct inspection time recorded in its MPS system (now RITS), we know of no cases where there was a satisfactory comparison. This tends to discredit the data in the the 766 system since the MPS is viewed as being an inherently more accurate system due to the built-in checks that we have previously described.
Timekeeping against inspection procedures has been advanced as a necessary meanc of building a budget. However, NRC budget decisions on IE programs are based in large part on MPS data (RITS) and on NRC management's and the Commission's
6
' L perception of which programs should be cut or increased. They are not generally based on detailed experience data from the 766 system.
There are two practical alternatives that the task force sees with respect to the time data in the 766 system:
1.
Timekeeping could be eliminated from the 766 system on the basis that it is unlikely to be used any more in the future than it has been in the last 10 years, that the data is inherently inaccurate, and that by eliminating the time data we would reduce the number of data elements in the system that could be a step in the right direction since, from the point of view of inspectors, there is a strong trend in the other direction.
2.
Time values could be assigned to each inspection procedure based on a carefully designed experiment or analysis to estimate what the time ought to-be in a typical case.
(There is a minority dissent from this possibility. That view is that assigning a time value 'to each procedure would be hard to determine and would lead to confusion. We coulc record total time per inspection type,.e.g., health physics, physical security, etc.)
Training and Orientation of New Insoectors on the 766 System There does not seem to be any routine, systematic procedure in the regions for acquainting new inspectors with (1) how the 766 data sheets are to be completed, and (2) what uses the inspector could make of the data. The majority of inspectors informed us that they learned about the system from another inspector.
In some cases, the inspector had read the 766 procedure in the IE manual with no additional indoctrination or training on the system. We are not aware of any systematic training that the regions were conducting at the time we visited the regions.
Regional management believes that structured training on the system is both desirable and needed.
b r
. Complexity The 766 form and system appears to the inspector to be unnecessarily complicated.
For instance, in addition to such frustrations as timekeeping, the inspector is asked to show which inspection module produced each item of compliance or deviation.
This is a relatively simple task in some cases and complicated in others because of the previously discussed matter of independent inspection versus planned routine inspection and unstructured inspection activities such as walk throughs and observations of work activities.
Another example is the column on Form 766 marked " Module Requiring Followup."
We wonder what use has been made of the data recorded under that category.
The same general thought arises regarding the data captured under the title
" Type of Activity Conducted." For example, when an inspector visits a site because of a reported event, should he/she indicate the activity as "03 Incident %
or "07 Special" or perhaps "02 Safety"? Five of the 15 choices only apply to safeguards inspections.
Perhaps there is a need to identify the% inspection in some fashion, but we doubt that these are the appropriate categories for the current program.
Data Elements Do Not Satisfv All Needs Noncompliance items currently can only be retrieved against the specific module number against which they were shown in the computer. They can not be retrieved by rule, SALP category, reactor system, Standard Review Plan Chapter number or other subject designations. The computer can make a word search but because of non-standard methods of entering noncompliance items such searchs are seldom successful and complete. The principal payoff in analyzing compliance experience may be to look at data in ways other than how the inspector charged the noncom-pliance to an inspection procedure. As an example, NMSS wanted to evaluate the noncompliance experience of the approximately 2,500 medical licensees as part of its project to completely rewrite 10 CFR 35.
However, due to the rigidity of the :ystem design IE was able to retrieve noncompliance data in only two cate-gories: all noncompliance items for doctors and all noncompliance for hospitals.
This necessitated a costly manual effort by NMSS to review and categori:e the data.
.g.
CONCLUSIONS 1.
There are certain self-evident needs for the general types of data that are contained in the 766 system. These are as.follows:
a.
Data about the status of program completion is needed to help IE carry out its oversight function. Is each region getting the planned program of inspection performed as envisioned in the allocation of FTEs for the current fiscal year?
b.
Data about the findings of inspections is desired to assist in program development.
c.
The regions have a need for tracking program completion. Generally, this is now attained by manually maintained systems, although the essential tracking data is in the 766 system computer but not inputted in a timely fashion due to system design and other fac' tors.
d.
There is the need to have overall data about numbers of inspections, frequency of inspection, and inspection findings to answer requests from Congress, the Commission, or others as to the extent of our inspection program and generally to characterize the nature of inspec-tion findings.
2.
System training and orientation of regional inspectors is spotty and not designed to motivate the inspector conscientiously to complete the computer input forms.
3.
Regional use of the 766 system is proportional to the ADP staff's ability to retrieve requested data in a relatively prompt fashion and to manage-ment's attitude toward the system.
If regional management views the 766 system as a necessary evil that must be accommodated solely because IE wants the data, then there is little use by the regional staff and little m:tive-tion to ensure hign quality data in the system.
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! 4.
Few inspectors derive any benefit from the 766 system. Some supervisors l
use the system for limited tracking of program completion and for evalua-ting enforcement but the principal regional use is to provide data as part of the SALP evaluation process.
5.
The main reasons that the regions make such limited use of the data are the delay of 2-3 months in getting the data into the computer and the inaccuracy of the data.
6.
Some improvements could be made in the current 766 system at a modebt' cost and with a significant payoff.
s a.
With minor changes tu the computer edit program, the basic infor7ation about each inspection could be entered into the computer within a day or two of the return of the inspector to'the regional office.
Subsequently, at a later date, and after NRC management signs the
'inspection report, the data about noncompliance could be entered into the computer. Questionable elements in the system cou}d be eliminated from the program so that the volu.ne of data would be reduced to that actually used and needed.
b.
Each region should be required to establish a QA program to ensure that data in the 766 system is reasonably accurate. (A revised draft IE Manual Chapter on that subject was given to the Director, Program Support and Analysis Staff, IE, some months ago.)
's c.
Each region should include a formal orientation on the 766 system in the training program nf each new professional employee. The orienta-tion should be presentec by a member of management, not an ADP techni-cian.
It should inform the new employee about how the data in the system can be used as well as the proper way to record data abcut his/
her inspection activities.
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1.
The 766 system procedura shorlo be modified (along with minor changes in i
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the computer edit program) so that inspection status' data about each 4
inrp/ction will be entered into the computer wittd:s a few days after. the C
,q end of an inspection.
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- ijt, The System should be modified to remove the tidkeeping data elementsi b
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a,,.1o other data elements of slittle value in.the managemenb, a,nd devele;' zen, t of,the inspection prohim.,,Ifneeded,indivIAalIEBranches,should" establish :n estimated time for completing each reutine'inQection pro-ceduNs. (There is a minority dissent to the use of estimath sima values.)
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3.
The IE Handl Chapter on the 766 system shov1d be completely rewhitt'en 1
L to rett. these goals:
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Place formal responsibility on the Regional Administrator 'fer tha i
j qual M,y and, timeliness cf tht regional data.
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t,3 Require updating of the system at least weeL y Basic'$spection program tracking data should be entered within one week of the last s
day of the. inspection.
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Require establishment of an orientation program to edure that'
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c employees are knowledgeable about how the system can 'n, used as.-
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h wellashowth'completetheformsandtomotivatethen.'tocareabout i
the accuracy of thy data. Orientation should be..b'y regional manage-4 ment.
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Require establishment of a QA system that meets specific, defined criteria to, ensure reasonable accuracy of the date in the system.
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IE should take the lead on efforts by Region II, III, V, and others to de>
a a flexible ADP system that puts the data from each inspection into
' cata base that can be manipulated to serve a wider range of needs than would the 766 system even with the recommended c.hanges. The effort to design a new system should be coordinated with the Office of Resource Management's project to establish a corporate data base for the agency.
If the new NRC concept can not accommodate a new automated data inspection and enforcement system within the next 24-30 months,-we should insist that the work be done independently from the project because it is a vital need of both the regions and IE.
5.
The Division (QASIP) should assign a technical program staff person full time to be the project leader for carrying out recommeMations 1-4 above.
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APPENDIX 3 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT IE MANUAL IO E I N CHANGE NOTICE NO.
76-35 SUPERSEDED:
TRANSMITTED:
Number Date Number Date gg See " Remarks" See " Remarks" DISTRIBUTION: Distribution List A REMARKS:
The enclosed instruction, MC 0535, " Statistical Data Reporting (766 Computer System)," is a complete reprinting of the manual chapter exc.pt for Enclosure D to MC 0535, " Catalog for Coding Items of Noncompliance & Jendor Program Deviations". The pre-vious version of MC 0535 and Enclosures A, B, C, E and F should be replaced with the attached instruction.
Principal changes made from the previous version are as follows:
- 1. Due to changes to Chapter 0800, items of noncompliance not cited are now re ferred to as " licensee identified items".
- 2. It is now required that a Form NRC-766-5 be completed for each item of noncompliance set out on a For: NRC-591 and that the text be the statement of the item of noncompliance as it appears on the Fors NRC-591.
- 3. The inspection programs currently modularited whose module num-bers should be used for reporting purposes instead of du==y modules are listed.
4 Certain modules are listed for which noncompliance should not be coded (page 17).
- 5. Recording inspection time against modules (pages 19 6 20).
{
- 6. Addition of Due=y Module 099018 for HTCR - Power Ascension Phase (Region IV).
- 7. Changes to terminology used in Blocks L and M on Form NRC-766, inf ormation block at the top of Form NRC-766, Side 2, and changes in terminology used on For. ' RC-766-S in Block A and the heading.
(Over.
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Note that module tracking information is now required for inspections made under the fuel cycle facility inspection program and the materials Module tracking information will be required for inspection program.
inspections made under the research reactor inspection program effective Ikh January 1, 1977.
Although changes have been made to Forms NRC-766 and -766-S, Regional Offices should continue to use current stock. Reorders for the forms will be filled with the revised versions.
The enclosed instructions were prepared by the Program Support Branch, 1
i
o U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT INSPECTION AND ENFORCEMENT MANUAL CHAPTER 0500 MC 0535 - STATISTICAL DATA REPORTING (766 COMPUTER SYSTEM)
TABLE OF CONTENTS gg, Page 0535-01 PURPOSE 1
0535-02 BACKGROUND 1
0535-03 OBJECTIVES 2
031 General 2
-032 Inspection Fees 2
-031 Minimizing Repetitive Data 2
0535-04 DEFINITIONS 3
-041 Inspections 3
6
-042 Inquiry 6
-043 Investigation
-044 Announced 7
-045 Unannounced 7
0535-10 INSTRUCTIONS - GENERAL 7
-101 Use of Separate Forms 7
8
-102 Report Numbering Syste
-103 Submitting Completed Forms 9
-104 Attachments to MC 0535 9
0535-15 FRE?ARING FCRM NRC 766 - FRONT SIDE 10
-151 Identifying Information 10
-152 Transaction Type 10
-153 Block A - Docket Number or License 10 Number (Byproduct)
-154 Block B - Report Number 11
-155 Block C - From Date (Inquiry /Investi gation/ Inspection) 11
-156 Block D - To Date (Inquiry /Investiga tien/ Inspection) 12
-157 Block E - Region Conducting Activity 12
-158 Block 7 Type of Activity Ccnducted 12
-159 Block G - Announced - Unannounced 12
-1510 Eleck H - Inspection /Investtgatien 12 Notification l
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-1511 Block I - Inspection / Investigation Findings 12
-1512 Block J - Number of Noncompliance Items in Letter to Licensee 13
-1513 Block K - Number of Deviations in Letter to Licensee NL
-1514 Block L - Number of Licensee Identified 13 Items
-1515 Block M - Numbe r of Abnormal Occurrences Reviewed Onsite this Inspection 13
-1516 Block N - Regional Of fice Letter or Report Transmittal Date for Inspection or Investigation 13 1517 Block 0 - Subject of Investigation 14
-1518 Block ? - HQ's Action on Insp. / Invest.
14
-1519 Block Q - Date HC's Enforcement Letter, Notice, Order Issued 14
-1520 Block R - Civil Penalty Issued 14
-1521 Block S - Date 766 Entered into Computer File 14 14
-1522 AITS Reference 0535-16 FREFARING FORM NRC 766 - SIDE 2 15 15
-161 Line Key
-162 Noncompliance (Right hand side of page) 15 i
0535-17 PREPARING FORM NEC 766 - SIDE 2 - MODULE TRACKINO INFORMATION - LEFT HAND SIDE CF PAGE 17
-171 General 17
-172 Form Precessing 17
-173 Corrections to Module Tracking Information 19
-174 Completing the Module Tracking Portien of Form NRC-766 15
-175 Guidelines - LWR Program: " Operations" Phase 24
-176 MTS Coding 24 0535-20 PREPARING FORM NRC-7665 26
-202 Block A - Type of Findings j
-203 Block B - Noncompliance and Deviation 27
/
Coding
-204 Block C - How Item Identified 29 l
-205 Block D - Consequences 29
-206 Block E - Exempt Information 30
-207 Block F - Additional Units 30
-208 Block C - Text 31
- _/2/Tc 11
O e
Page 0535-30 PREPARING FORM NRC 766 FOR 766 MASTER 32 FILE CHANGES 33
-301 General 33
-302 Responsibility 33
-303 Form Processing
-304 Deleting Entire Record from 766 Master File 34
-305 Modifying an Existing Record on 766 Master 34 i
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSFECTION AND ENFORCEMENT INSPECTION AND ENFORCEMENT MANUAE CRAFTER 0500 MC 0535 - STATISTICAL DATA REPORTING (766 COMPUTER SYSTEM) 0535-01 PURPOSE The 766 computer - based information system has been developed to improve organizational effectiveness and efficiency in'the areas of. collection, processing, retrieval, analysis and management of inspection relsted data. This data, a combination of statistical, planning and textual information, is recorded on Forms NRC 766 and 7665 for eventual entry into the computer.
This chapter provides the-instructions for the completion'and handling of the Forms NRC 766 and NRC 766S for the various statistical, planning and textual data concerning inspection, investigation, inquiry and associated enforcement actions conducted by the Office of Inspection and This instruction also discusses the responsibilities of Enforcement.
the appropriate persons f or filling out the for=s and forwarding the completed forms to headquarters for processing.
0535-02 BACKGROUND The 766 System is a management tool used to capture, maintain and report statistical and planning data concerning inspection, investigation, inquiry activities and associated enforcement actions conducted by CI&E.
The data is captured via the Forms NRC 766 and NRC 7665 and maintained on a computer disk file at the National Institutes of Health (NIH)
The 766 forms.are used to record basic statistical l
Computer Center.
data concerning each inspection, investigation or inquiry, related Module Tracking System information, nonce =pliance statistics and the text related to each item of noncompliance, Licensee Identified Ice =,
Data from the forms feeds into the 766 statistical data and deviation.
the= Module Tracking System to update the inspection scheduling and
- file, planning networks, and the Enforcement Text System which provides monthly input for the various Rainbow Books.
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The forms function as computer input forms and, accord-ingly, information must be recorded in strict compliance with certain conventions and criteria as discussed later in this chapter. Incomplete, inaccurate or illegible data entered on either form will result in the introduction of faulty data into the statistical data file, the Module Tracking System (MTS) and/or the 766 Enforcement Text System. The result of faulty data vill be extra man-hours of regional inspector and headquarters personnel time to trace and correct the errors.
0535-03 OBJECTIVES 031 General The System has been designed to record in one place pertinent management-oriented information for each inspec-tion, investigation and inquiry of concern to =anagement i
and includes:
a.
The number and types of inspections and investigations, b.
The number and nature of inspection findings with associated text of noncompliance item and deviation.
c.
The action taken and by whom, d.
The numbers and types of modules inspected and related statistics, e.
Elapsed time statistics.
032 Insoection Fees The Form NRC 766 has been designed in anticipation of
- assessing inspection f ees (type of inspection, routine-fee and no fee). No decision has been reached regarding the imposition of inspection fees; therefore, no further discussion or specific instructions on this matter will be made at this time.
Should such fees be assessed, additional instructions for implementation and coding vill be distributed.
033 Minimizine Repetitive Data The NRC 766 and 7665 forms have been developed with the objective of minimizing the number cf times inspection 5/;C/70
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4 MC 0535 related data must be recorded for entry into computer based information systems. The basic 766 system serves as the primary source of all statistical information relating to inspections, investigations, in-quiries and enforcement. The 766 Enforcement Text System serves as the
. primary source of all text on items of noncompliance, Licensee Identi-fied Items as - il as deviations. The 766 Module Tracking System is
, gg, the source of basic data for maintaining the facility inspection networks as well'as the source of statistical data on module inspection practices. Since these data bases function as the source of official historical data and the source of information for the Module Tracking System and the enforcement text for the various " rainbow books",
it is important that data be entered completely and accurately.
0535-04 DEFINITIONS This section defines the types of activities (inspection, inquiry, investigation) listed in block F of Form NRC 766 and the terms announced and unannounced appearing in block G.
Any conflicts between definitions appearing herein and these appearing in MC Section 1205 (under develop-ment as of June 9, 1975) are to be resolved.in favor of MC 1205.
041 Inspections a.
Routine (02) l Construction, quality assurance, operational safety, radio-logical health and safety, environmental protection and emergency planning inspections performed at prescribed frecuen-cies and in accordance with the procedures and instructions l
covering the routine inspection program as described in the IE Manual. Safeguards inspections (material accountability, plant security, etc.) and vender inspections are not included here.
Routine inspections are structured such that through one or more inspection visits over a period of ti=e a complete review l
will be made of major activities authorized by an author-l ization, construction permit or license. For some licenses the review may be completed in one inspection visit each year, each two years, etc., in other cases portions of the review are made during each of several inspection visits made durinc a yearly period.
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_4 Frequently during a routine inspection visit, a review will be made of the status of previously identified enforcement matters, reported incidents f
or abnormal occurrences and other matters identified Ik6 for followup review.
At this time, all routine inspections will Note:
be coded F Routine (no fee). Block F Routine (fee) will not be used, and accordingly no instructions have been prepared setting forth criteria for distinguishing between the Fee and No Fee classification of Routine inspections.
b.
Incident (03)
Unscheduled inspections performed as a result of an incident or abnormal occurrence reported by a licensee, or reported by others as having occurred at.a licensed f acility or associated with some aspect of a licensee's activities, involving construction deficiencies, equipment failures, exposure to radiation, release of radioactive materials, loss of use of a facility, property damage, accidental criticality, contamination problems, loss or theft of material, transportation, and similar types of unusual or unforeseen events.
c.
Enforcement (04)
Sonroutine inspections performed for the exclusive purpose of reviewing in a timely manner a licensee's corrective action or response to significant items of noncompliance identified during a previous inspection. Such inspections may be performed prior to or subsequent to the issuance of a notice of inspection findings to the licensee.
d.
Management Audit (05)
Comprehensive team inspections, scheduled as a result of programmatic requirements or as a result of inspection findings, which focus on the management aspects of facility licenses for purposes of ascertaining how the corporate entity, as an NRC licensee, is organized to effectively implement regulatory requirements as they related to nuclear safety.
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Management Visit (06) l i
Those periodic visits to facilities, performed as l
a result of programmatic requirements, the main l
purpose of which is to inform the licensee management j
of IE inspection practices and methods. Such
)
g, visits normally occur shortly after a utility has l
indicated to NRC that it will or intends to apply for a construction permit and whenever the inspection responsibility shif ts between various groups or branches in a Regional Office.
The visits do not involve fact gathering activities.
f.
Special (07)
Nonroutine inspections performed when it appears that significant regulatory require =ents are not being fully complied with, or when potential safety items have been identified, and prompt resolution of matter is required by the licensee to assure continued safe operations.
A special inspection may include the performance of routine inspection items, g.
Vendor (CC)
Inspection activities performed of those companies or organi:ations which co= prise the architect-engineer, nuclear steam system supplier, and component supplier groupings identified in the vendor program, or the continuation of such vendor inspections that might be conducted at a licensed facility.
h.
Material Control and Accounting (Matl Acct) (09)
Inspections performed in the areas of material control and accounting and licensee measurement programs covering all components of measurement used for material control and accounting purposes.
(Safeguards only) 1.
plant Securiev (10)
Inspections performed for physical protection of SNM at fixed sites and of plants in which SNM is used for the purpose of protection against acts of industrial sabetage and thefts cf SNM.
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Inventory Verification (11)
Inspections performed to evaluate licensee programs for accounting of SNM and for the conducting of~
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physical inventories in order to provide independent assurance that the licensee's program is capable of detecting losses or diversion of SNM.
k.
Shipment / Export (12) 1.
Shipment (of SNM)
Inspections performed in the area of physi-cal protection of SNM in-transit for the purpose of protection against theft and sabotage.
2.
Export (of SNM).
Inspections and independent verification to determine the element and isotopic content of all exports of SNM to assure integrity of such shipnents and to ascertain whether physical security requirements are being met.
1.
Imports (of SNM) (13)
Inspections and independent verifications to determine the gross quantities and integrity of import shipments of SNM to assure that the licensee, upon receipt of the shipment takes required actions.
042 Inouiry (14) i of investigative An inquiry is an activity wherein a minimum amount technique (telephone, correspondence, or in-office review of material) is used to determine if an investigation, a routine f
{
or special inspection, or no action is required as a result
)
of (1) an allegation, complaint or report related to licensed
)
facilities or materials, or materials subject to licensing, or (2) inaction by a recipient to an order issued by NRC (see MC 1210 for further information),
043 Investigation (15)
An investigation is an activity conducted in response to a complaint or an allegation to gather, correlate and evaluate f
material in depth for the purpose cf establishing the cause, i: ::. - T s e
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MC 0535 nature, extent and particulars of a condition or occurrence; the status of compliance with Regulatory Requirements; adequacy of actions being taken by a licensee; assistance needed by a licensee; and corrective actions needed to minimize or preclude such conditions or occurrences. An investigation for a matter other than a complaint or al-legation may be requested by IE:HQ'S.
(See FC 1210 for Eks f urther inf ormation.)
044 Apnounced An inspection or investigation visit is considered to be announced if the licensee has been informed by IE personnel, through any verbal means, prior to the actual arrival on site that one of these activities is to be conducted by one or more inspectors. Announcement can take the form of a written communication, telephone call from home, office or hotel prior to actual arrival on site, or orally informing any member of the licensee organization that a visit may or will be made at some specified time or date.
043 Unannounced An unannounced inspection is one where the licensee, or members of the licensee organization, is not notified by the inspector of an inspection or investigation until the inspec-tor (s) arrives on site or at the place shere the inspection is to be conducted.
0535-10 INSTRUCTICSS - GENERAL 101 Use of Separate Forms A separate form 766 is prepared for each unique activity conducted, i.e., a separate form for each inspection, investigation and inquiry performed which results in an inspection or investigation report (letter to the licensee) and an inquiry report. There must be a one-to-one relation-ship between an " activity", whether it be an inspection, investigation or inquiry, and a " report".
(The activity number and the report number will be synonymous).
A " report" may consist of nothing core than a Form NRC-591 and related documentation.
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Whenever items of noncompliance or deviations have been identified in the report to the licensee, a form NRC 766S, appropriately marked, must be completed for each such item, even if the report is only an NRC for=
Furthermore, if there are Licensee Identified Items referred to 591.
or discussed in the report, a form NRC 7665 must be completed for each Ikm l
such item.
102 Report Numbering System The numbering system for activities will be as follows:
The combination of the docket number and report number is the controlling identification for each activity reported to the 766 system.
For each licensee, facility or vendor the first inspection, s.
investigation or inquiry conducted in each calendar year will com=ence with the number 01 preceded by the Isst two digits of the year and run consecutively throughout the year, i. e., the first report for any ac-etc. for tivity related to a particular licensee, vendor, applicant, 1975 will be 7501 and the second report will be 7502 etc.
One numbering system covers inspections, inve;tigations and inquiries.
g b.
For persons other than licensees, applicants and vendors,
'I each inspection, investigation or inquiry report must have a unique report number within each regional office. The first such report for each calendar year will com=ence with number XX01, the second report XX02 (where XX represents the year - 75, 76, etc.), regardless of theof fact that dif ferent individuals or organizations may be the subj ect the activity (see also Section 0535-153 & 154).
When a single " report" (or letter to the licensee) is written c.
for activities concerning more than one facility or license, a separate Form NRC 766 must be prepared, along with the appropriate NRC 7665 forms, for each facility or license involved in the inspection er investigation.
(The single written report is in essence a multiple report with unique report numbers for each facility or license).
d.
For " assist" inspections, the Region responsible for corres-pending with the licensee (issue a 591 or letter) will complete and Care must be taken submit the appropriate 766 forms to Headquarters.
to coordinate with the Region holding the license that a correct report number is given to the activity. Only one unique report number for each activity is allcwed in the computer system (duplicate report j
numbers f or a particular docket number will cause the record to be rejected). Regions involved in inspections of licenses with multiple locations cf use must coordinate on the report numbering system.
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example, a Region I license having authorized places of use in Region I and Region III requires that Region I and Region III work out an acceptable report numbering scheme - e.g., Region I uses even numbers and Region III uses odd numbers, or Region I uses numbers 01-50 and Region III uses numbers 51-99.
103 Submitting Completed Forms gg Completed Forms NRC 766 and NRC 7665 are to be reviewed by the Regional Information Systems Coordinator before being sent to the Office of the Assistant to the Director, Headquarters. Completed forms should be submitted on a weekly basis. This will allow headquarters to enter the 1
input data and update the master file weekly rather than once at the end of the month. This will result in a quicker update to the 766 Files and therefore more timely access to the data. The Form is considered complete when the Regional Office has entered data in all required sections and:
. A Form NRC-591 is issued; or
. A letter (report) has been sent to the licensee following an inspection or investigation; or
. A report or inquiry sent to Headquarters for action has 'oeen acted upon by Headquarters and the resulting documentation sent back to the Region for completion of the Form.
In the future the regions will be responsible for entering their own data into the computer for updating. Detailed instructions and training will be provided prior to i=plementing this procedural change.
104 Attachments to MC 0535 Enclosure A - For: NRC 766 - Form NRC 7665 Enclosure C - The list of " Codes of Deviations" 11/ 2.' ~ s
. MC 0535 Enclosure D - The " Catalog for Coding Noncompliance and Vendor Program Deviations."
Enclosure E - The list of HQ Action Codes Ok Enclosure F - Listing of Du=my Module Numbers 0535-15 PREPARING FORM NRC 766 - FRONT SIDE The individual who is in personal charge of the inspection /
investigation / inquiry is responsible for what appears on the Form NRC 766. Those parts of the form completed by the Regional Office staff can be filled out by anyone in the Regional Office, including the clerical staff. Nevertheless, the individual-in-charge (the principal inspector or senior) should review the form for correctness before it is sub-mitted to Headquarters. Headquarters related information is entered on the form by the Regional Office staf f upon receipt of action notification and related correspondence from HQS.
The following are the items on the front side of the NRC 766 form and the instructions for completion:
151 Identifying Information The Facility Name, Licensee / Vendor Name, Principal Inspector, Inspector (s) (for this inspection, etc.) and the Reviewer items at the top of the page are to be filled in but the data is not captured by the computer.
This space has been provided for regional office use and the items are self-explanatory.
152 Transaction Type There are three Transaction 'Iypes for deleting (recoval of an entire 766, 7665 record previously entered in:o the system),
inserting (adding a new 766, 766S record to -he coeputer system) and modifying records (changing part of a record).
For a period of time all forms marked delete or modify aill require coordination between IE:HQS and the appropriate Regional Office Coordinator or inspector.
153 Block A - Docket Number or License Number (By-Product) 1he appropriate 8 digit numeric Docket Number (e.g., 03004960, 05000341, 07000216), or project number (00000476) for non-docketed f acilities is to be recorded f or all activities involving reactors, special nuclear caterial, source and priority ! taterial licensees. For material licenses other than priority I it is preferable that the appropriate 03C)DDas.
docket number be used; however, the Ey-?roduct License Number s ':: -
4
!!C 0535 can be recorded on the. form'and the corresponding Docket Number will be entered by the computer.
The License Number must be entered exactly as it appears on the license (include hyphens, leading zeros and left justify).
Examples: 45-00317-01E SUB-520 XSNM-453 Docket Numbers for Vendors and A/E's are the unique 999xxxxx number for each.
The Docket Number to be recorded for a non-license is 9999000R, where R is the numeric Region Number (e.g., for Region I - 99990001, Region II - 99990002, etc.).
The Docket Number is one of the key fields that uniquely defines the records in the syste=.
Be extremely careful not to make errors in coding as a time consuming manual correction effort will result.
154. Block B - Report Number The appropriate 4 digit numeric (e.g., 7501) Report Number should be recorded with the first 2 numerals for the calendar year and the second 2 numerals for the report.
Refer to 0535-102 above for a more detailed explanation of the report numbering requirements.
Within in each region the reports for non-licensee Docket Numbers (e.g., Region I 99990001) must be uniquely numbered, commencing with XX01 for each calendar year.
The Report Number is one of the key fields that uniquely defines the records in the system so be very careful not to make coding errors.
155 Block C - Trom Date (Inouiry/ Investigation / Inspection)
Enter the date,that the activity began in the fortat MMDDYY
. including leading zeros (e.g., 010175, 100175).
If out-of-office direct effort was involved, enter the date it began but do not include travel time.
If no out-of-office effort, enter the date in-office direct effort began.
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MC 0535 156 Block D - To Date (Inquiry / Investigation / Inspection)
Enter the date that the activity ended in the format MHDDYY
%g including leading zeros (e.g., 011675, 100675).
If out-of-office direct effort was involved, enter the date it ended but do not include travel time. If not out-of-office, enter the date in-office effort ended.
NOTE: Regarding blocks C & D.
If the effort began and ended on the same date, enter this date in both C and D.
157 Block E - Region Conducting Activity Enter the code for the Regional Office conducting the activity, whether or not the facility listed in Block A is in that region.
Use numerals 1 thiough 5 to indicate the region.
158 Block F - Tvpe of Activity Conducted r
. See 041 f or definitions.)
If box 15
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Check only one box.
(investigation) is checked also check one box in block 0.
t Until further notice do not use the box 01 (Routine-Fec).
See Sections 03 (Objectives) and 041.a for an explanation.
159 Block G - Announced - Unannounced Check the appropriate box (see Section 0535-044 for definitions).
1510 Block H - Inspection / Investigation Notification For inspections and investigations record the completing action by checking the appropriate box. Also complete data blocks in N.
1511 Block I - Inspection / Investigation Findings t
For inspections and investigation check only one box to record the appropriate findings.
If there are only not cited items of noncompliance, the inspection should be checked as Clear (Box 1).
If there are not cited items 1
of noncompliance and deviations, the inspection should be j
checked as Deviation (Box 3).
NOTE :
(See also 0535-202 c.) All citable iters un-covered during vendor inspections are to be indicated as Deviations.
This is also indicated in Bleck B and on 7665.
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MC 0535 1512 Block J - Number of Noncompliance Items in letter to Licensee Record the number of cited items of noncompliance identified in the letter to the licensee. This number must correspond with the number of noncompliance codes recorded on the back of the NRC 766 form as well as the number of NRC 7665 forms completed for cited items of noncompliance E%g or the entire input record will be rejected by the computer program.
1513 Block K - Number of Deviation Items in Letter to Licensee
~
Record the number of deviation items identified in the letter to li-censee. This number must correspond to the number of NRC 7665 forms completed for items of deviation or the entire input record will be rejected.
1514 Block L - Number of Items Identified by Licensee Record the number of ite=s identified by the licensee. This number must correspond with the number of NRC 7665 forms completed for Licensee Identified Items or the entire input record will be rejected.
1515 Block M - Number of Licensee Events Reviewed Onsite this i
inspection Record the appropriate number of " Reportable Evedts" reviewed onsite.
1516 Block N - Regional Office Letter or Report Transmittal Date for Inspection or Investigation The Report Transmittal Date (Block N) must be greater than or equal to the to date (Block D).
a.
591 or Letter Issue Enter the date that the letter or Form 591 was sent to the licensee by the Regional Of fice in the format MMDDYY including leading zeros (e.g.,
020175, 110175).
b.
Report Sent to H05 Report Sent to Headquarters for Action - Do not enter any information in this block unless the report is sent to Headquarters for enforcement action or, for an inquiry a report is written.
Enter the date in the format MMDDYY including leading zeros (e.g., 020175).
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. MC 0535 1517 Block 0 - Subject of Investigation Check the appropriate box (one only) if and only if box 15 (investiga-tion) in Block F is checked.
The following items (Blocks P thru R) should be completed by the Eks regions after being notified by HQS of the action taken. Copies of all HQS actions and correspondence are sent to the field and consequently the regions will have the source documents needed and would be more informed than HQS to complete the ' forms:
1518 Block P - HQ's Action on Insp./ Invest.
Referred by Region.
Enter the appropriate numeric code only if HQ's action is required (Block H. Box 3 or 4 is checked).
See enclosure E for coded list of HQ's actions.
1519 Block 0 - Date HQ's Enforcement Letter, Notice, Order Issued.
Encer the date that a Headquarters Enforcement Letter, Notice or Order was issued only if Block P is completed.
Enter in the format MMDDYY and include leading zeros (e. g., 010975).
A 1 1
1520 Block R - Civil Penaltv Issued.
Check this box if a nttice of proposed imposition of civil penalty was issued.
152: Block 5 - Date 766 Entered into ce= outer File Inter the date (conth, year) that 766 Fer= will be inputted to the computer in the format MMYY and include leading zeros (e.g., 0175, 0975).
(
I 1522 AITS Reference.
Enter AITS reference if applicable.
This information is to be entered by the regional office and will be used for reference purposes by Regien Coordinators and the OAD staff.
This data is not captured by the computer
- system, l
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. 'MC 0535 0535-16. PREPARING TORM NRC 766 - SIDE 2 The following are the items on side two of the NRC 766 form and the instructions for completion:
The "B".in the first column has been pre-printed'and is used by the computer system for reference purpose only, it is not entered into the system.
'lg 161 Line Key.
The line Key colunos (2 and 3) are used internally by the computer system for referencing specific lines of Module Tracking Data and Noncompliance Codes. The units position has been pre-printed but the Tens position must be completed.
If only 1 NRC 766 back side is used for recording MTS and Non-J compliance data nothing need be recorded in column 2, the tens position.
If a second NRC 766-back page is to be used, the Continuation box at the bottom of the first 766 back page is checked, and the tens position on the second back page is filled with the number 1, i.e., the first line on the continua-tion page will read B10, the second line B11, etc.
If a second continuation page is needed (i.e., more than 20 line entries), the first line of that page vill need B20.
162 Noncompliance (Richt hand side of page).
Enter the noncompliance codes for : hose items of noncompliance identified in the enforcement letter or on a Form NRC 591 (Do not include Licensee Identified Items). Where a mocular inspection program is in effect, i.e., inspection procedures have been defined in the IE Manual, the codes should be entered on the line with the corresponding Module that was being inspected at the time the noncompliance was uncovered.
If core than 5 noncompliance codes are identified with a particular Module, continue the codes on the next line in the proper area on the form.
If inspection procedures have not been established (see Section 171 for modularized programs), a dummy module must be entered (See Enclosure F for the module number and instructions) and enter the coded items of noncompliance relating to the dummy module, if any.
The noncompliance code entered should be a 4 digit alpha numeric code as follows:
The first three positions are for the Requirements Code -
See Enclosure D, Catalog for Coding Item of Soncomp11ance and Vendor Program Deviations.
The fourth and latt posit;cn is for the Severity Level
(
assigned to tha ncaccepliance item in the enforcemen:
(
letter. The coding of th-Severity will be made as follows:
11/2/76
(
4
l' 16 -
- Violation 2 - Infraction 3 - Deficiency (The coded severity level noted in the catalog is to be used only as a guide in determining whether noncompliance should be designated as a violation, infraction or UL deficiency).
If multiple back pages of the NRC form.are used to code modules inspected and/or noncompliance, be sure to check the continuation box at the lower right hand side and to increment the ten's position value of the line key by 1 as noted in sub paragraph 0535-161 above.
0535-17 PREPARING FORM NRC-766 - SIDE 2 - MODULE TRACKING INFORMATION - LEFT HAND SIDE OF PAGE 171 General Inspection staff performing inspections must be familiar with the various manual chapters covering inspection programs and procedures in j
l order to correctly provide statistical information concerning modules u
(procedures) and to comply with the requirements of this section.
Supervisors should ensure that all personnel reporting to them provide the required information correctly and in a timely manner.
The following programs are currently modularized and the appropriate module numbers should be used for reporting purposes instead of du==y module numbers.
MC-2500 Reactor Inspection Program
-2510 Light Water Reactors 1
-2520 HTGR
-2540 Research Reactors (Effective 1/1/77) l MC-2600 Fuel Cycle Facility Inspection Program
-2610 Reprocessing Facilities
-2620 Plutonium Facilities
-2640 Uranium Facilities
-2650 UF-6 Conversion Facilities
-2660 Uranium Mills i
-2670 Fuel Receiving & Storage Facility
-2680 Fuel Facility Safeguards Inspection Program MC-2700 Licensee Contractor & Vendor Inspection Program
-2710 Nuclear Steam System Suppliers i
-2720 Architect Engineering Firms
-2730 Independent Suppliers
-2740 Third Party Inspection Organizations l
11/2/76 G
. MC 0535 l
MC-2800 Materials Inspection Program j
-2820 Processors and Distributors
-2830 Radiography
-2840 Waste Disposal
-2850 Industrial, Academic, Environmental, Source Material and SNM (other than Fuel Cycle Facilities covered by MC 26xx series),
I Other specific licenses g
-2860 Medical
-2870 Shipping casks, Transportation This part of the form has been developed to provide a vehicle for the recording and collection of basic data concerning the status.of the The data inspection program as applied to each individual facility.
thus collected will be used to update the Module Tracking System and other associated program management systems. The data recorded on Form NRC-766 also will be stored separately in the 766 file for future reference and analysis.
The Module Tracking Information part of the form will also be used to
, relate all cited items of noncompliance listed in enforcement corres-pondence to a specific procedure (module) or a programmatic function or activity (dummy module) as discussed in Enclosure F.
be In all instances where noncompliance is listed a module number must recorded or the form.
The use of this form will require that, for each inspection performed, the inspector record:
a.
What modules were inspected, b.
What modules were co=pleted, What modules were left open, c.
d.
How much of each module was inspected (%), and e.
How much time was spent.
Do not~ code noncompliance against modules which are intended to inform the licensee of our programs, summari:e inspection results (such as 30702, 30703, 30800) or follow-up on actions or events for which noncer-pliance would be charged to an inspection module.
172 Form Processing the results One or more Side 2 of Form NRC-766 vill be used to document of each inspection. The Module Tracking Information portion of the For-SRC-766 provides for the recording of information on each module
- 11. :
l
t MC 0535 inspected and relate it to the inspection trip and report. For each module number entered on the form, the status, the percent complete, and the professional manhours expended are recorded.
l In those instances when team inspections are performed, each individual inspector is responsible for providing the inspector-in-charge with all data pertaining to his own inspection effort, I
necessary to complete the MTS input.
(All information required by the 766 must be provided in a manner which will allow the inspector-in-charge to correctly complete a 766 form for data processing.)
The MTS input _ from the individual participating inspectors should be consolidated into a single 766 covering that inspection.
Any questions concerning proper completion of the Module Tracking Portion of Form-NRC 766 should be directed to the designated contact, Office of the Assistant to the Director or the desig-nated regional coordinator.
173 Corrections To Module Tracking System Information n
A MTS printout for each facility will periodically be provided to the Regional Office.
This is available to review, co= pare with 766 submissions and to mark up with any changes or corrections which may be necessary to the MIS data base. The =arked-up printout will be returned through the appropriate supervisor to the MTS Coordinator.
Corrections to the MTS data base must be handled by contacting tbc designated Regional Infor=ation Systems Coordinator. He will prepare new MTS inf ormation as appropriate, based on the information given, and will update the MTS computer files accordingly.
(See also 5174.d below.)
174 Coepleting The Module Tracking Portion Of Form NRC-766 A specific rJ06ula cust be listed on the 766 whenever any time has been expended on it during the inspection.
SOTE: In those cases where a module is not to be inspected at all, or the " window of opportunity" has irretrievably passed er will pass before another inspection can be performed, notify either the Regional Information System Coordinator er the designated !I:HCS contact whc will appropriately close out the module by
(
inserting 0; co=plete, O nan hours and add a "C" directly into the appr:priate '4:5 network, by passing the 766 System.
11/2 76
)
~
~
MC 0535 The specific data elements present on the form are to be co=pleted as follows:
J a.
Module Number Inspected: The seven-digit number
)
assigned to this inspection module. The module number is composed of four parts: Phase, Manual Chapter, Procedures, and Level of Effort, for a total of seven i
Ibn positions.
Phase - A number from C to 6 indicating the phase of the facility. Phases 1 to 6 are LWR phases and Phese 0 is for dummy modules:
Phase 0 = Dummy Module (see enclosure F)
Phase 1 = Pre-CP (MC-2511)
Phase 2 = Construction (MC-2512)
Phase 3 = Pre-Operation (MC-2513)
Phase 4 = Startup and Power Ascension (MC-2514)
Phase 5 = Operation (MC-2515)
Phase 6 = Decommission (MC-2516)
Manual Chapter - The first two (2) digit number of the I&E Inspection manual chapter nu=ber which contains the inspection procedure being documented.
Procedure Number - The three (3) digit number fro = the I&E Manual which identifies the discrete inspection procedure being documented.
Level of Effort - The one (1) alpha character corresponding to the A, 3, or C level of effort to be expended.
(All are B level at present.)
SOTE: A codule number may be entered on the individual 766 form only once.
The recording of a ecdule nu=ber more than once is not valid except in the case of module number 92701B.
b.
Marhours Expended This Report: For each module listed indicate the total professional manhours of direct inspection effort expended on completion of the line 1
items in this module during the period covered in this report by all inspectors who participated. Only '.,* HOLE H0t*RS are recorded.
The syste= does not accept tenths of hours.
Therefore, for any inspection involving two or more modules it may be necessary to show 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for some modules on the 766 fore so as not to distort the distribution of ti=e spent en modules or to inflate the total time actually spent on the inspection.
For 11/2/M
________________o
. MC 0535 l
example, if the total site time is in the order of 1 or l
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the 15 or 20 minutes spent on 30703 should not l
be rounded up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. A distorted picture of the inspection could result.
The following guidance is suggested to prevent introduction 14, of misleading site (Direct Inspection Effort) hours into the 766 system. Record 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> against 30703 if for an the total man hours of direct inspection effort inspection is less than (a) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or (b) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and The total inspection less than 1/2 hour is spent on 30703.
time should be recorded against the major inspection module used.
The regional staf f will have to exercise judgement on other variations, such as use of 9xxxx modules and combinations of program inspection and exit different in order to maintain a correct balance interview time, to exceed of reco*rding time against modules so as not the total time actually spent conducting an inspection.
The only manhours to be reported here are as follows:
4 1.
Out of Office Inspection Effort, which includes onsite and offsite inspection effort, and 2.
In Office Inspection Effort, which includes the inspection of licensee records; fact-gathering activities which are more ef ficiently perf ormed in the office than at the licensee's facility; and an extension of the field inspection process, but performed in the office.
Only the time actually required to complete inspection of the line items contained within a specific module should be attributed In the event problems or potential problems are to that module.
identified during the completion of a module, the time expended in resolving the problem should be attributed to the appropriate follow-up module 92701B.
NOTE: Direct inspection effort does not include preparation for an inspection; documentation of and reporting the results of the inspection; preparation of regular and enforcement corres pondence; or travel to and from the site.
f c.
?ercent Complete to Date:
For each module listed, :he
)
percent complete is a judgment on the part of the inspector reflecting the amount of effort expended as a 1;/:/~6 l
j
MC 0535 percent of the total effort to be eventually required as defined by the Manual.
(In instances where all the individual 1.tne items of a procedure cannot be accomplished because of the nonexistence of referenced systems, components, reports, etc., then the percent of total effort should be based on what is applicable at that facility.) The percent should be rounded in multiples of 10, and must be cumulative to date. For example, if a gg module was reported 70% complete C.te first time it was inspected, and the remaining 30% uns completed on the second inspection, then the module status form documenting the second inspection would show a total of 100%, i.e.,
the actual total percent complete at the time of the report. 100% is the maximum entry.
Computation for Determining % Complete Total Manhours Expended Through Current Inspection X 100 = %
Total estimated Manhours Needed to Complete Module NOTE: Do not enter Percent Complete or Status on Form 766 for Module 30703, modules in the 92XXX, 93XXX and 94XXX series, or modules designated "When Recuired."
d.
Status: For each module listed, indicate the appropriate status code, as follows:
Blank = Open: Leave open, this module is to be inspected further on a subsequent inspection.
C
- Closed: A closed condition can be achieved via 766 input eat y in only one of two ways, as follows:
1.
When all line items have been inspected - 100P. of the work effort for the module has been completed.
(Any unresolved items, deviations, non-compliances, or other problems encountered will be followed up under the applicable general inspection procedure in the 92XXX series.)
2.
The opportunity for completing a partially inspected module (the " window") will pass before the next inspection regardless of the actual completion status.
[In this case the work performance may have been some percentage less than 1000, but the opportunit;. to achieve 100*; has passed and the module should be considered closed f or all practical uring the i
purposes.]
The module is closed
~~ d current inspettict.
j lif1/Te
,7 M', ' -
T
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2 y
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MC 09.5 l
1
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s 1
4 If a module is never to be inspected, the T
Regional Information Coordinator should be i
notified so that module can be closed out at 0%
1 complete with 0 man hours. Also if a module has been partially cottleted and it be, been decided that no more work vill be performed on it, then i
/
?
the Regional Information C.>ordinator should'be notified tci close out the nodule, The 766 form 5
should not be used'to perform either type of closure.
,It is.important to remember that the required NOTE:
inspection frequency, or window cf opportunity for repetitive inspection requirements, is specified in the programmatic manual chapters, not by the MTS printout. For example, MC 2500 requires that modules with a quarterly inspection f requency be completed four tic.es per year at intervals of no less than two months and no more than four months. Thus the actual window of opportunity for a particular quarterly module and the MTS schedule date for that module may at times I
vary.
L = Reopen and Leave Open: This code'is used in cases
'l l
where a module was previously closed (based on the J
assumption that opportunity to do more work has passed) but 'the inspector is able to do additional work on a j
previously closed module and now wants it left open indefinitely. By using the L code, the module is reopened and left open indefinitely or until the inspector decides to close ic later.
p = Reopen for This Transaction Oniv: This code is used in a manner similar to the i code above, except that a module closed previously will be reopened to receive additional manhours or a revised percent complete oscimate for this one occasion only, and will then be cicsed.
.OTE: Certain modules are never closed by the inspector.
N These include Module 30703, modules in the 92XXX, 93XXX and c4XXX series, and any module designated "*n~nen Required" (indicated by a "'w'" in the enclosures to the programmatic manual chapters). Therefore, " Percent Complete" and " Status" do not apply to these modules and these two columns should be left blank on the form.
These =cdules will be closed out on a yearly basis by the Regional Cecrdinator er Ecadcuarters staff.
11/2/76
_____-_____-____-_ m
1 o
e MC 0535 e.
Modules Requiring Follow-up When a problem or potential problem is identified by the inspector during the com-pletion of a module, the time expended in resolving the problem or potential problem should be attributed to Module 92-701B (Follow-up on Inspector Identified Problem). The module being inspected when the problem or potential problem is identified should be recorded g,
in the column " Module Req. Follow-up." Each module requiring follow-up should be documented on a separate line on the module tracking information portion of the 766 form.
f.
Guidance for use of module 92701. Any time spent following up on what are normally referred to as
" unresolved items," or other time spent on resolving problems identified during accomplishment of a specific module should be reported under 92701 with the appropriate module listed as requiring follow-up. As an example, during the review of log books specified in 71710-Review cf Plant Operations, the inspector may infer that the number of inoperable control rods exceeds the limit specified in technical specifications. The time expended for follow-up inspection effort on the control rod prob-lem is reported under 92701 with 71710 listed en form 766 as the module requiring follow-up.
In contrast, a situation may arise which is totally unrelated to the module (s) being inspected., As an example, if during the conduct of the inspection pro-cedure 71710, an explosion occurred in the OFF-GAS system at a BWR facility, the inspection time expended f or the follow-up or this unplanned event will be charged against 93701 - follow-up on significant event that occurs during inspection. Conduct of the inspection procedure 71710 in no way leads to the identification of the " problem".
Guidance for Use of " Independent Inspection Effort" g.
Reported under Module 92706 As stated in Section III of the procedures for this module, the defined inspection requirements contained in the manual are to constitute 80% of the allotted onsite inspection effort. 20% of the inspection effort is available to the inspector fer activities outside the defined inspection program.
"Outside" the cefined inspection program means that the activity exceeds the frequency, 11/:/ 7
4
. MC 0535 scope, sample size, etc., prescribed in other modules. For example, if the inspector examines aspects of core physics, fire protection, training, velding, modifications, etc., which are not included in g
the inspection procedures, the time would be charged against module 92706. Likewise, any noncompliance identified by the inspector during the additional inspection effort would be coded against Module 92706.
As with prescribed modules, time spent following up on resolving items identified during independent inspection effort is charged against Module 92701 with Module 92706 listed as the module requiring follow-up.
175 Guidelines - LWR Program: " Operations" Phase Quarterly, refueling and annual modules must be closed out indicating the end of cycle "N" before inspection results can be reported against the same module numbers for cycle "N + 1".
176 MTS Coding The examples contained in the follouing section are provided in an attempt to eliminate confusion and nonuniformity in reporting module status, i.
Infor=ation was available for inspection, but the inspector had insufficient time during the inspection trip to complete the module as scheduled but sufficient time remains to complete the module during a future inspection and meet the required inspection frequency for the module.
(See information concerning window of opportunity under Section 174.d.2.)
ACTIONS REQUIRED If inspection effort was expended en the cedule.
a.
list it on the 766 and provide the required data, leaving the module open.
If no inspection effort was expended, do not list module on 766.
b.
Include the module in a subsequent inspection as necessary to meet the required frequency.
c.
List the module on the subsequent 766 fcts, recording appropriate status, 2.
Inf ormation was available fer inspection, bu: the j
module was not completed and cannot be rescheduled t:
- 1/1/76
MC 0535 meet the required inspection frequency or window of opportunity.
(See information concerning window of opportunity under Section 174.d.2.)
ACTIONS REQUIRED Uk a.
Enter the module number on the 766 and close the module indicating the actual percent complete.
Note:
If no inspection effort has been expanded on the module, notify the Regional Information g
System Coordinator who will arrange to close the module at 0% complete by separate processing action. This action must be accomplished before the MTS will recognize inspection effort expended on the module during the next inspection interval.
3.
Information was not available for inspection to permit module completion within the required inspection frequency or due to some other circumstance the module was not inspected.
ACTION REQUIRED a.
Notify the MIS coordinator to close out the module.
4.
All line items were inspected but the findings on one or more line items were unacceptable (i.e., noncompliance, deviations or unresolved items).
ACTIONS REQUIRED a.
List the module on the 766 and close it at 100%
complete.
b.
Identify all noncompliance, deviations and unreselved items in the Su= mary and Details of the Inspection Report.
c.
Follow-up noncompliance deviation or unresolved item under Module 92701 during subsequent inspection.,
l S.
Effective October 1, 1976, modularized inspection procedures for materials licensees and fuel cycle j
facilities were put into effect. At that time use of the dummy modules (see enclosure T, MC 0535) for most, i
if not all, inspection activities should have stopped.
I 11/;/71
4 I
LMC 0535 Inspections and investigations starting af ter October 1 vill require recording of the new inspection module numbers on side 2 of the 766 form:
lIn Each routine materials inspection will involve the use of at least three modules -
f 30703 - mgant meeting / exit interview-except for multiple site
[
92706 - independent effort 7xxxx - specific program procedures Initial inspections will also require the use of 30800 -
initial agent meeting.
Nonroutine inspection activities will require use of appropriate "when required" modules in addition to 30703.
Fuel cycle facilities will involve more modules.
The reprocessing, uranium and plutonium facilities which involve more than one inspection per year will require the use of several modules each inspection - some completed each inspection, others partially completed. Other fuel facilities most-likely will i
be inspected once/ year and all appropriate modules should be shown for each inspection.
0535-20 PREPARING FORM NRC-7665
'2 Block A. Type of Findings There are three Findings Types which can be reported on 766S:
a.
Box A.
NONCOMPLIANCE - found during inspections and investigations conducted by the Office of Inspection and Enforcement or reported by licensees and then reflected in the associated enforcement actions.
For each noncompliance case identified on an NRC 766, INCLUDING those involving issuance of a Form 591, this box must be checked and the form completed.
l b.
Box B.
LICENSEE IDENTIFIED ITEMS - Under the procedures contained in Manual Chapter 0800, certain items reported by licensees are not included in the enforcement correspondence from the Regional Office or headquarters to the licensees.
Specifically those items in the infractien and deficienev
- ..'I ' 7 5
____________________-----O
l MC 0535 l categories which have been identified by the licensee, where corrective action was taken and appropriate documentation made or reports submitted are in this category.
For each item identified by the licensee which
(
does not appear in the Notice of Violation this box must be checked and the form completed.
c.
Box C.
DEVIATION - When a licensee does not conform to commitments to the Commission, or to the provisions of guides, codes and standards or to acceptable practices which,were approved by the Commission and made available to the licensee and such lack of conformity does not constitute an item of noncompliance, then it is referred to as a
" deviation."
Chapter 0800, Section 0802.08 defines deviation.
Section 0850.03 contains guidance regarding citations for deviations. Manual Chapter 1005, " Inspection Documentation - Routine Inspections," discusses documentation requirements for deviations (Section 1005-25).
Citable items uncovered during vendor inspections which are considered to be deviations from the 18 Quality Assurance Criteria will be coded as deviations.
See the Section I, Part B Catalog for Coding Noncompliance Items and Vendor Deviations for coding of these items.
For each deviation identified which appears in a correspondence for a particular inspection or investigation, this box must be checked and the for= completed.
203 Block B.
Noncompliance and Deviation Coding a.
Specific Noncompliance or 1.icensees Identified Items -
l This field is completed if Box A or B of Block A is checked. Enter the 6 position noncompliance code as derived from Enclosure D.
See page iv of the Introduction Section of the " Catalog" for examples of noncompliance coding.
.. /.' ~ t s
. MC 0535 The first three positions for the requirements code - Section I, Part A of Enclosure D.
The fourth position for the cause code -
gg,Section II, Enclosure D.
The fifth position for the inspection procedure code - Section III. Enclosure D.
The sixth position for the severity level assigned to the noncompliance item. Coding will be as follows:
1 - Violation 2 - Infraction 3 - Deficiency See also Section 0535-162 of this chapter for coding of severity levels. The severity coding on the 766 and 7665 forms must agree.
l (The coded severity level noted in the catalog is to be used only as a guide in determining whether noncompliance should be designated as a violation, infraction or deficiency.)
b.
Specific Deviation - This field is completed if Box C of Block A is checked.
In the IDENTIFICATION block, enter the 3 to 5 character identifying code from either Section I, Part B " Vendor Deviation Codes," Enclosure D or the list of commitments, codes, guides, standards, or acceptable practices shown in the attached
" Code of Deviations," (Enclosure C).
This section represents the set of codes, guides or standards against which deviations were cited.
In the SPECIFIC GUIDE OR STANDARD block enter the number or other symbol that identifies the specific subset cf the code, guide or standard noted in the IDENTIFICATION block.
]
Example 1.
If the deviation was from Regulatory Guide 1.16 then the field wculd ze coded in the fellowing =anner:
'.1.T '!:
i l
i
L MC 0535 1.
The appropriate code for Regulatory Guide would be found in the list of codes, guides and standards found in Enclosure D.
This Code (REGGD) would then be coded into IDENTIFICATION block.
On
- 2., The guide number 1.16 would be coded in the first 4 positions of the SPECIFIC GUIDE OR STANDARD block and the last 6 positions would be left blank.
l Example 2.
If a citation were made against ANSI N18.7, the coding in Block B would be:
1.
ANSI would be coded in positions 1-4 of the IDENTIFICATION block.
2.
N18.7 would be coded in positions 1-5 of the l
SPECIFIC GUIDE OR STANDARD block.
No reference is made to the particular section of the standard.
- 204 Block C. - How Item Identified Check the box that best describes who identified the ite: of noncompliance or deviation.
L - identified by the Licensee (if Box A, B, or C of Block A is checked)
I - identified by the Inspector (if Box A or C of Block A is checked) 0 - other (such as representatives of the state or local jurisdiction or private individuals) (if Box A or C of Block A is checked) 205 Block D. - Consequences
)
Enter the code that best describes any consequences of the ite:
i of Noncompliance or Deviation.
A - caused or constituted an actual occurrence" (if Box A or C of Block A is checked) p - had potential to result in an actual occurrence (if Ecx A, B, or C of Block A is checked) 11/2/76 1
MC 0535 N - did not have potential to result in an actual occurrence (if Box A, B, or C of Block A is checked) kk
- An occurrence is defined as an event that has some safety sig-nificance (may or may not be covered as a reportable incident in regulations).
206 Block E. - Exempt Information In those cases where data to be included in Block G (Text) deals with those areas which are exempt from public disclosure under 10 CFR 2.790, place a check in the space provided. This will suppress the printing of this item of Noncompliance or Deviation in the Gray or Yellow Book or other public disclosure.
207 Block F. - Additional Units NONCOMPLIANCE (Box A or Block A checked) a.
In some instances, during an inspection trip at a multi-unit power reactor station, a specific item of noncompliance is found that does lead to a citation against more than one unit at that station.
In these cases either the enforcement correspondence or the report details, or both depending upon circumstances would reflect the fact that the item of noncompliance or deviation was charged to each of the involved units. A separate Form 766 for each unit so cited =ust be prepared.
LICENSEE IDENTIFIED ITEMS (Box B of Block A checked) b.
In some instances, an item reported by a licensee, involving a multi-unit power reactor station, may at that be associated with nore than one unit station.
DEV!, TION (Box C cf Block A checked) c.
In some instances, deviations at a multi-unit power reactor station may be associated with more than one unit at that station.
I i
d.
When anv of the above situati:ns occur:
)
1.
Enter "M" in pcsition 1 of :he field.
2.
In pcsitiens 1, 3, and 4 ci the field enter in numerical sequence the designation cf :he
'. 1 ~
i l
l
1 l HC 0535 l
other units which have also been cited for this item of noncompliance or associated with this deviation or Licensee Identified Item.
3.
Example 1.
During an inspection at the Dresden site an item of noncompliance or L
E%g deviation is identified which is charged to units 1, 2, 3.
On the Form 7665 for Dresden 1 in Block F enter M23 On the Form 766S for Dresden 2 in Block F enter M13 On the Forn 766S for Dresden 3 in Block F enter M12 l
The text field is repeated on each of the three 766S forms.
Example 2.
During an inspection at the Harris site, an item of noncompliance or deviation is identified which is charged to units 2 and 3, but not 1 and 4.
On the Form 7665 for Harris 2 in Block F enter M3 On the Form 7665 for Harris 3 in Block F enter M2 The text field is repeated or both of the 7665 forms.
The purpose in doing this is to be able to identify those units uniquely having noncompliance or deviations and also to be able to identify noncompliance or deviations common to more than one unit.
208 Block C. - Text a.
NONCOMPLIANCE Each item of noncompliance must be described in detail to include the applicable requirement and the factual information that demonstrates that an item of noncompliance existed.
(The require-ment should be referenced, not described.
!f j
cited, this item should appear essentially as j
l 11/:/76 i
)
m o
I j
. MC'0535 it appeared in the enforcement letter to the licensee.
The text should be developed in accordance with the instructions in Chapter 1000. Samples of " Notice of Violation" from which the narrative should be taken can g,
also be found in Section 0875 of Chapter 0800.
If the item of noncompliance is associated with a NRC Form 591, the text is to be the statement of the item of noncompliance as it appears in the NRC Form 591. For example, the text of a citation for failure to post a radiation area would be " Rooms or areas were not properly posted to indicate the presence of a radiation area."
b.
LICENSEE IDENTIFIED ITEM Each item must be described in detail to include the applicable requirements.
(The text should be developed as described in Section 208.a.)
c.
DEVIATION Each deviation must be described in detail to include the item not complied with and the factual infor=ation that demonstrates that a deviation existed. In general, the applicable ce=mitment, code, guide, standard or accept-able practice should be referenced, not described.
L'sually, the ref erence must be specific.
In some cases, in order to clarify the applicable commitment, code, guide or standard, it may be necessary to provide a brief description in addition to the reference. This ite should appear essentially as it appeared in the letter to the licensee. The text should be developed in accordance with the instructions in Chapter 1000, Manual Chapter 2005, Section 1005-25.
Provisions have been made for capturing up to 800 characters of text for nonco=pliance and deviation items. Should the actual text of the ite=, in appearing in either the enforcement letter or the report details, exceed this nu=ber it will be necessary to paraphrase the item to keep within 800 characters. Nothing precludes para-phrasing all such items, but it should be remembered ths the text as recorded in 7665 will be used verbati: as the input to the Enforcement Status cf the " Rainbow" bocks.
0535-30 PREPARING FORM NRC 766 FOR 766. ASTER FI'.E CFx;GES
- <. 7t
. MC 0535 301 - General Once a record has been created on the 766 Mastar File, i.e the 766 form (s) have been processed and the data entered into the computer system, modifications to the record for that inspection, inquiry or investigation are made through the use of the same form (NRC 766) that l
Ikm was used to originally create the record.
NOTE: Forms NRC 766 and NRC 7665 cannot be used to medity information in the Module Tracking System (MTS) or the Enforcement Text System. Changes to these files must be done directly in the appropriate system through your regional or the headquarters coordinator, Changes to the MTS data in the 766 Master File record can be made via the NRC 766 form but it is important that the same changes are also made in the M6dule Tracking System and vice versa. Any changes to noncompliance and/or deviation counts'or codes must be made on bath sides of the Form NRC 766 as appropriate as well as to the Enforcement Text System directly via INQUIRE.
The key to uniquely identify records in the 766 Master File is the Docket / Report Number combination. To uniquely identify the 766 Master File segments containing the MTS and related noncompliance (cited) codes, the unique Line Key (For= NRC 766 - Side 2) is needed along with the Docket / Report Number combination.
302 - Responsibility As the regions accept the responsibility for their own 766 data entry and pre-edit processing they will also be responsible for the accuracy of the 766 Master File.
This will require the use of Form NRC 766 to delete and modify the 766 Master File data.
The Regional Information Systems (MIS) Coordinator will be responsible for coordinating record modifications with the regional inspectors and 1
verifying the use of the NRC 766 forms to insure the integrity and accuracy of the 766 Master File.
303 - Form Processinc The NRC 766 forms used to modify or delete records on the 766 Master File will be processed along with the regular weekly 766 input data through the 766 System.
The completed forms for deleting or modifying records can be placed anywhere in the weekly input data set. An 11/1 ri
1 i MC 0535 internal computer sort routine vill organize the input data prior to the updating of the Master File.
304 - Deleting Entire Record from 766 Master File If a record gets created with an erroneous docket and/or report kk number, the only way to correct this type of error is to totally delete the incorrect docket / report record and re-enter it under the correct docket / report number combination.
To dclete an entire record, a Form NRC 766 with the Delete box checked under Transaction Type and the appropriate Docket / Report Number combination must be completed and entered into the 766 System. The entire record must then be entered under the correct Docket and Report Number as necessary (see Sections 0535-15 and 0535-17).
305 - Modifying An Existing Record on 766 Master File To change data in an existing 766 Master File record, the Modify box under Transaction Type must be checked and the docket and d
report numbers of the record to be changed must be completed no matter if the field (s) to be modified are on Side 1 and/or Side 2 of Form NRC 766.
NOTE: It is important that corresponding changes are made to all fields (s) which have a data relationship.
a.
Modifying Fields (s) on Side 1 Complete only those fields that are to be replaced with the new information you want to appear on the 766 Master File. If a field contains data and it is to be blanked out, it must be replaced with zeros.
NOTE: Never replace the Date 766 Entered field unless the originally entered date was incorrect.
b.
Modifyine Field (s) on Side 2 To make corrections to Form NRC 766 - Side 2 data (MTS and Noncompliance), the entire line (766 Master File segment) must be replaced. The exact Line Key (From 766 Master File) of the data to be replaced must be coded along with the complete line as it is to appear in the Master file. Also, "R".
This code will be used by the computer system to generate :ne transaction X
i 11 :': ' M
Q MC 0535 record to delete the line (segment) and a second transaction record to create the line with the neu data. If you want to blank out an entire line (segment),
code the appropriate Line Key and the Replacement Code and leave the rest of the line blank.
c.
Inserting Line(s) on Side 2 gg To insert a new line (segment) into the 766 Master File, code the Line Key field with a unique key (Line Key that does not exist) followed by the module information and appropriate noncompliance codes. Do Not enter the Line Replacement Code as this will cause a transaction error when the system attempts to delete a seg=ent that does not exist.
NOTE: Prior to coding a record to modify or insert an NRC 766 - Side 2 segment, it will be necessary to coordinate the change with your Information Systems Coordination for a comparison of the current 766 Master File record.
9 6
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- C 0535 r.. closure A-1 NoveCber 2. 1976 FORV No: 766 use.Tso statis tuCLsaa agoutatoe s coupession le"o'((5! " *'
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MC 0535 Enclosure C CODE OF DEVIATIONS CODE NAME OF COMMITMENT, GUIDE, CODE, OR STANDARD
COMMITMENTS
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PSAR PRELIMINARY SAFETY ANALYSIS REPORT FSAR FINAL SAFETY ANALYSIS REPORT APPL APPLICATION CVTR VENDOR TOPICAL REPORT OCOM OTHER COMMITMENTS TO NRC(NRR, NMSS, AND I6E)
GUIDES
REGGD REGULATORY GUIDE NO.
STANDARDS OR CODES
MiSI A"IRICAN NATIONAL STANDARDS INSTITUTE ASME AMERICAN SOCIETY OF MECHANICAL ENGINEERS ASNT AMERICAN SOCIETY FOR NONDESTRUCTIVE TESTING N;S AMERICAN NUCLEAR SOCIETY ASTM AMERICri SOCIETY FOR TESTING MiD MATERIALS IEEE INSTITUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS ASA AMERICMI STANDARDS ASSOCIATION ACI AMERICAN CONCRETE INSTITUTE NFPA NATIONAL FIPI PROTECTION ASSOCIATION EPA ENVIRONMENTAL PROTECTION ADMINISTRATION NEMA NATIONAL ELECTRICAL MXiUFACTURERS ASSOCIATION AWS AVIRICMi WELDING ASSOCIATION ASCE AMERICKi SOCIETY OF CIVIL ENGINEERS ANIM ASSOCIATION OF NUCLEAR INSTFUMENT MxiUFACTURERS ESSA ENVIRONMENTAL SCIENCE SERVICES ADMINISTRATION NAS NATIONAL ACADEMY OF SCIENCES NBS NATIONAL BURIAU OF STANDARDS INMM INSTITUTE OF NUCLEAR MATERIALS MANAGEMENT ISA INSTRUMENT SOCIETY OF AMERICA SCP.P NAT!0NAL COUNCIL ON RADIATION PROTECTION MC MF.ASUREMENT l
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MC 0535 Enclosure C OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION OSHA USAS USA STANDARD OTHER STANDARDS OR CODES (SEE NSIC 112 OR LATER OSOC EDITION)
ACCEPTABLE PRACTICE
g GENERALLY ACCEPTABLE PRACTICES IN TIE INDUSTRY 3 API d.
2
O MC 0535 Enclosure E List of HQS Action Codes j
Action Code g,
No action required 01 Letter issued to licensee 02 Part 2 Notice Issued to Licensee 03 Order issued 04 Proposed Civil Penalty issued 05 Referred to licensing for resolution 06 Referred to Region to close out 07 Other reason 08 O
s ENCLOSURE F (REVISION II) l DUMMY MODULES (PROCEDURE) NUMBERS i
l Use of these modules, in the absence of an appropriate procedure number for those p:ograms currently modularized, is required for each inspection and investigation (see Section 171 for a list of modularized programs). The purpose of the dummy module number is to provide a record of the direct inspection effort and related gg, items of noncompliance associated with those specific (or general) programmatic functions or activities conducted by IE which are not. presently modularized.
The modules are to be used for all activities whether clear and not clear. For each dummy module entered on the 766 Form, record the hours of dirtet inspection effort and any noncompliance according to the instructions under MC 0535 Sections 174 and 162 re s pe c tiv y,1y.
The use of these modules will enable the field inspection staff to further define the nature of the various activitics included in an inspection, and the corresponding inspecticn report, as shown in Block F of Form NRC 766.
For example, a routine inspection of a fuel facility may have included a review of nuclear safety, radiological protection and plant security.
Only box 02 (Routine - No Fee) of Block F on Form NRC 766 can be checked; however, recording of various " dummy" modules on side 2 of the form under Module Tracking Information, will enable the region to show the various major inspection elements included in this report.
The Phase in the Module Number Inspected lield must always contain a zero (0) when a " dummy" module number is being used.
List of "Du=v" Modules Module Identification Module Number (Including Phase)
Abnormal Occurrence 099001 Emergency Flanning 099002 Environmental Protection 099003 General Health & Safety 099004 Material Control & Ace't 099005 Nuclear Safety 099006 Plant Security 099007 Radiological Protection 099008 Reactor Construction 099009 Reactor Safety 099010 I
Transportation 099011 LWR's Under Construction (to be deleted) 099012 LWR's Being Decommissioned 099013 Investigations 099014 3 Mile Island Inspections per Sandia Study 099015 Test 6 Startup (Region II) 099016 Vender Inspection 099017 HTGR - Power Ascension Phase (Regi:n */
09901E
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9
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I 2-MC 0535 ENCLOSURE F (REVISION II)
For modularized programs (see Section 171 for a list of modularized programs) use the applicable procedures (modules) g that have been established in the 9200, 9300 and 9400 chapters for all types of reportable, nonroutine and unplanned activities.
For all other programs that are not modularized use the
" dummy" modules.
Use of these codes is on an interic basis pending incorporation of inspection requirements into the IE manual.
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APPENDIX 5 U.S.
NUCLEAR REr.ULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT INSPECTION AND FNFORCr. MENT MANUAL l
1 CHAPTER 0500 NC 0535 - STATISTICAL DATA REPORTING (766 COMPUTER SYSTEM) 0535-01 PURPOSE The 766 computer-based information system has been developed to im rove organizational effectiveness and efficiency in the areas of collecticn.
processing, retrieval. analysis and msnagemont of inspection related data.
This data, a combination of statistical. planning and tcutual information is recorded on Forms N2C 766 and 766A.
This chapter provides the instructions for the comojetion and handling of the Forms HRC 766 and 766A for the various statistical, planning and teutval data concerning inspection. Investigation, inquiry, and associated enforcement actions conducted by the Office of Inspecticn and Enforcement.
.The instruction also discussos the responsibtlittes of the appropriate persons for filling out the forms.
0535-02 BACKGROUND The 766 System is a management tool used to capture, maintain onc rescrt statistical and planning data concerning inspectiun. investigation, inquiry activities, and associated enforcement actions conducteo oy !E.
The data is captured via the Forms NRC 766 and NRC 766A anc mairtste-cu on a comcuter disk file at the National Institutes of Health (NIH)
Computer Center.
The 766 forms are used to record basic 5 ctistical cata concerning each_ inspections investigation or inquiry, related Module Tracking information. violation statistics and the test relo:ec to each item of violation and deviation.
The forms function as computer input forms and, accordingly.
1information must be recorded in strict conpliance with certain conventions and criteria as discussed later in this chapter.
Incomplete. inaccurate or illegible data entered en eithea 3ce-result in the introduction of faulty data into th? statistic 31 c ic bnse.
The result of faulty data will be estra stiffhcurs of rep :"3; inspector, and Region Computer Staff anc hencGV3rters Of*5c' e.
- 0 to trace and correct the errors.
l 0535-03 OBJECTIVES 031 General The System has been designed to record in c9e clace pe*!'ac--
3**:?-
ment-oriented information for each inspection. investiga ic-3 :
inquiry of concern to management and incluces;
....?
I'....
a.
The number and types of incpnctione and snvestigoteunc.
b.
The number and nature of inspection findings with I
associated teat of violation item and deviation.
c.
The action taken and by whom.
d.
The numbers and types of modules inspected and related statistics.
e.
Elepsed time statistics.
032 Mini =:rino meeetitive Data The NRC 766 and 766A forms have been developed with the objective of minimizing the number of times inspection related data mus1 be recorced for entry into computer based information systems.
The basic 766 system serves as the p r,i m a r y source of all statistical information' relating to inspections, investigations, inquiries and enforcement.
It also serves as the primary source of all test on items of violation and deviations.
Data from the system is used to analyze various aspects of the inspection progroms; answer inquiries from Congress, the Ccmmission and other sources; provide part of the basis for budget requests; help in the analyses of enforcement cases; and provide requested data to licensees and contractors regarding the compliance records of licensees.
Since this data base serves so many important purposes, it is important that data be entered completely and 1ccurately.
l 0535-04 DEFINITIONS - TYPE OF ACTIVITIES CONDUCTED (Columna 37/35)
This section defines the types of activities (:nspection. inquiry.
investigation) licted in columns (37/3C) of Form NRC 766.
041 faseeetiens a.
_5s#ety (02)
Construction, quality assurance, coerational safety, radiological health and safety, en/ironmtntal p+ctcetion and emergency planning inspections per'ormed at nrescrited l
frequencies and in accordance with the p-ccecu*es s";
instructions covering the routine inspection Oregr5-as f
decribed in the IE tianual.
fafeguards ins:ect:c s
-:te*:s; l
accountability, plant security, etc.) anc seacce
-e-: :- tes are not included here.
Routine inspections are structured such that throven sae er more inspection visits over a ceriod of ti e a cone:ete
'c.ie-I will be made of major activities astneri:ec by a l ' -- tte c'-
l authorization construction cernet or license.
Fe-sc e cases the revsew may be cen 10ted in one inspectica. ecy year. every two years or every three years.
In cine * ::s2s portions of the review are nace during each of seve*al inspection visits made curing a yea *1y peried.
ln/52 I
1
___J
Pago 3 Frecuently during a routine inspection visit, a review will be made of the status of previously identified enforcement matters. reported incidents or abnormal occurrences and other matters identified for followup review.
b.
Incident (03)
Unscheduled inspections performed as a result of an incident or reported by others as having occurred at a licensed facility or associated with some aspect of a licensee's activities. involving construction deficiencies. equipment failures, exposure to radiation, release of radioactive materials, loss of use o.
facility. property damage, accidental criticality, contamination problems, loss or theft of motorsal, transportation, and similar types of u n u e. u a l or unforseen events, c.
E"*ercement (04)
Nonroutine inspections performed for the esclusive purpose of reviewing in a timely manner a licensee's corrective action or response to a significant item of violation identified toring a previous inspection.
Such inspections may be performed prior to or subsecuent to the issuance of a notice of inspection findings to the licensee.
i d.
"anneement Audit (O$)
Comprehensive team inspections, scheduled as a result of programmatic requirements or as a result of inspection findings which focus on the management aspects of facility licenses for purposes of ascertaining how the corporate entity, as an NRC licensee, is organized to effectively implement regulatory requirements as they relate to nuclear safety, e.
Mannee-ent visit (06)
Those periodic visits to facilities, performed as a result cf programmatic requirements, the main purpose of whien is to inform the licensee management of IE inspecticn practices and methods.
Such visits normally occur shortly ofter a utility has indicated to NRC that it will Jr intenes to ancly Joe &
construction permit and whenever the inspection resecasio' lit /
shifts between various groups or brancnes in a Regional
- e.
The visits do not involve fact gathering activities.
I'l/E' 1
L
)
1 I
i Page 4 f.
Sencial (07) i Nonroutine inspections performed when it appears that k
significant regulatory requirements are not being fully I
complied with, or when potential 5 :s f e t y items have been identiftede and prompt resolution of matter is renvired by the licensee to assure continued sife operatiens.
A special inspection may include the performance of supplemental inspection items.
p.
Vender (08)
Inspection activities performed of those companies or organizations which, comprise the architect-engineer. nuclear steam system supplier, and component supplier groupings
';dentified in the vendor program, or the c ont inuo t t or-of such vendor inspections that might be conducted at a licensed facility.
h.
Material
'C o n t r e ! and Accountime (Mptl Acet) (09)
Inspections performed'in the areas of material contrcl and accounting and licensee measurement programs covering all components of measurement used for maternal control and accounting purposes.
(Safegyards only) 1.
clamt See$ci*v (10)
Inspections performed for physical protection of SNM of flued sites and of plants in wis i c h S N!! is used for the puroese c4 protection against acts of industrial sabotage and thefts DJ SNM.
J.
!mventeev Veeldiention (11)
Inspection performed to evaluate licensee pecgrars ice accounting of $NN and for the concveting of OhystC31 inventories in order to provide incecencert assure 4ce that the licensee's pro 9 ram is capable of cetectiag !csses or civersion of SNH.
k.
Shiement/Evneet (10) 1.
Shipment (of SNM)
Inspections perfoemec in the area C f crysical cettect :-
of and SNM in-transit eer t$e puccese of prete:t C-against theft and sacetage.
k i
o Page 5 2.
Export (of SNM)
(
I I
Inspections and independent verificaelon to determine the element and isotopic content cf all exports of SNM to assure integrity of such s h i p re e n t s and to ascertain whether physical secursty requirements are being met.
1.
Ymeerts (of SNM) (13)
Inspections and independent verifications to determine the gross quantities and integrity of import shipments of SNM to assure that the licensee, upon receipt of the shipment takes required actions.
042 Inculev (14)
An inquiry is an activity wherein a minimum amount of investigative technique (telephone, correspondence, or in-office review of material) is used to determine if an investigation. a routinS or special inspection, or no action is required as a result of (1) an cliegation, complaint or report related to licensed facilities or materials, or materials subject to licensing or (2) inaction by a recipient to an order issued by NRC.
043. h stlentIen (15)
An investigation is an activity conducted in response to a complaint, incident or an allegation to gather, correlate and evaluate material In depth for the purpose of establishing the cause. nature, extent and particulars of a condition or occurrenect the status of compliance with Regulatory Requirements; adequacy of actions being taken by a licensee; assistance neeoed by a licenseet and corrective actions needed to minimize or preclude such conditions or occurrences.
An investigation for matters other than a complaint or allegation may be recuested by IE: H0, 0535-10 INSTRUCTIONS - GENERAL tot Ura e'
766/766A Forms The 766/766A forms are designed so that when inspections of the same activity types are conducted, they can be recorded on the same 4:r.
If each inspection action is unique, a separato form 766/766A i s prepared.
Wnenever items of violation or deviation have been identified in the report to the licensee, a 766A form must ce completed.
4 i
Page 6 102.Reeert Numbeeine Svstem
.e numbering system for activities will be as follows*
The combination of the docket number and report number is the controlling. identification for each activity reported to the 766
- system, s.
For each licensee. facility or vendor the first inspection.
investigation or inquiry conducted in each calendar year will commence with the number 01 preceded by the last two digits of the year and run consecutively throughout the year.
i.e..
the first report for any activity related to a particular licensee. vendor, applicant, etc., for 1901 will be 8101 and the second report will be 8102. etc.
One numbering system covers inspections, investigations and inquiries.
b.
For persons other than licensees. appilcants and vendors. each inspection, investigation or inquiry report must have a unique report number within each regional office.
The first such report for each calendar year will commence with number XX01.
the second report XX02 (whero XX' represents the year - 80. 81.
etc.), regardless of the fact that different individuals or organizations may be the subject of the activity (see also Section 0535-153 and 154).
c.
The revised 766/766A Forms minimizo administrative paperwork for inspectors.
Inspectors nay now enter results of several inspections,. where types of activity conducted are ident6cale on a single form.
However, a 1: e p a r a t e report number must be issued for cach inspection.
d.
For " assist" inspections. the Region responsible for corresponding with the licensee (i.sve a 591 or Ictter) will eseplete ano input the data on the 766 f le.
Care must be taken to coordinate with the Region holding the license that a correct report number is given to t he :ic t i v i t y.
Only one I
uniave report nunber for each actisity i t. allowed in the computer system (duplicate report numbert for a carticular docket number will cause the record to be rejected 1.
8egiens involved in inspections of licenses witn multiple locatiens l
of use must coordinate on the report num 2rin; syste*.
ce erample. a Region I license having authorized claces of use in
{
Region I and Region !!! reavires t 'i s t Renien I assign a reccat number to Region III for these inspections conc'actec ey Region III.
l ef a-.
a
'c Page 7 e.
For inspections performed by a Resident Inspector or a Performance Appraisal Team the regional office in which the Inspection was performed will be responsib!c for assigning a Report Number and performing the 746 data entry function:.
The 766/766A forms should be completed by the Resident inspector or Performance Appraisal Team and sent to the appropriate regional office.
103 submittino ceanteted Forms Completed Forms NRC 766 and NRC 766A are to be reviewed by the Regional Information Systems Coordinator before beinq entered into the computer J
system.
Completed forms should be e n t e r e ti ento the computer on a weekly basis.
This will result in a Quicker update to the 766 file and therefore, more timely access to the data.
The Form is considerec complete when the Regional Office has entered dato in all required sections and2
- A Form NRC-591 is issued; or
- A letter (report) has been sent to t.
licensee following an inspection or investigation.
104 Attachments te MC 0535
)
Enclosure A - Form NRC 766 Enclosure D-Form NRC 766A
~
Fnclosure C Dummy Modules (Procedures) Numbers Enclosure U
- Code of Deviations FRONT SIDE (Columns 1/55) 0535-15 PREPARING FORM NRC 766 3
The supervisor of the principal inspector who is in direct charge 0 the inspection / investigation /incuiry is responsible for what accecrs en the Ferm NRC 766.
Those parts of the form completed by the regicaal of# ice staff can be filled out by anyone in the regional office.
including the clerical staff.
Nevertheless, the individual-in-charge (the principal inspector or senior resident) should review the for-for correctness.
The following are the items on the NRC 766 for-aac the instructions for completion 8 151 Tdentifyino indermation The Licensee / Vendor Name, Principal Inspector.
Inspector (s) (for this inspection, etc.) and the Reviewe* items at the top of the page are to be filled in but the cata is not cactur:0 by the computer.
This space has been provsceo fcr regional of# ite use and the items are self-esplenatory.
. / '. ' M
i 4
Page 8 152 Teaasmetion Tvre (Column 1)
Se four transaction types used to capture and maintain data in the 766
.ata vase are:
- Insert to add a new record to the data base Modify to alter information in the data base to remove a record from the dots base Delete Replace to rewrite textual data in the data base Detailed instructions on these transactions are found in the Users Guido.
153 An c_k _t Number c-License Numbee ( P. - P e n ri e tt_).
(Columns : /tc) f The appropriate 8 digit numeric Docket Number (e.g.,
03006960.
05000341) or project numuce (00000476) for nondocketed facilities is recorded for all activities involving reactors, special nuclear noterial, source and priority I material l i c e n s e 'e s.
F.o r material licens*S other than priority I It is preferable that the appropriate 030XXXXX docket number be used; however
.the Dy-P oduct License Number can be recorded on the form.and the corresponding Docket Number will be entered by the computer.
The License Number must be entered exactly as it appears on the license (include hyphens, leading zeros and left justify).
Esamples:
45-00317-ole SUB-520 X5NM-453 Docket numbers for vendors and A/E's are tha unieve 999%XXXX number for CDCh.
The docket nunber to be recorced for a non! cense is 999900: 4.
where R is the numeric region numoer (e.g.,
for :- oien 1 - 99990001. Regi:n II - ?a990002, etc.).
The Docket Number is ene of the key fie'ds that unicuely dc*ines the records in the system.
Be entreme!' care 4ul not to m u. e errors in coding as a time consuming ma:. val : rre: tion eff: t will result.
154 Deeert Numb *e (Columns 15/18)
The appropriate 4 digit numeric (e.g..
sic 9 ) Deo *: Nv see sa:,1: :e recorded with the first 2 numerals for the :alenua* year and tre s r. : : ~ :
O numerals for the resort.
Refer to 0535-t~0 a:: e +:r a ere :et: ';e2 esplination of the reoort n u :n = e r i n g reeviremea*3 Within cach region the reports fer nonlicersee :::ket eU-be*$ (E4 5.
e rgeon ! 99990001) must be uniquely numbere:. ::- encin9 it, X%'
sch calendar year.
The Report Number is one o*
the key fiel=s that unicuely
'e*
- ?!
the records in the system so ce very careful not to *3ko :::'"~
crfors.
'. ' b
e Page 9 155 alnha etnuenca codeg (A.
B.
C, D1 (Column 19)
When there is more than one ine,pection of the same type performed. the alpha sequence codes are used in recording veta of di f f erent docketc on the same forn.
When filleng out the f o r re. the inspector choVlo cay special attention to the docket / license number. Columns 2-14, inspection / investigation findings. Column 39, tot 31 number of violations and deviations. Columns 40-41, enforcement conference held.
Column 42. report contain 2.790 information. Colven 43. module tracking information and on 766A. site related. Coluan 25.
156 Fevt insnection omlf fontionall This date is supplied by the inspector ofter a material license i n e.p e c t i o n is performed.
It is used by the MIS Coordinator to update the material master file only.
157 8.a d t_qf Investicatien/In=nactiqn (Columns 20/31)
If the effort began and ended on the same date, ente
- this cate in both Columns (20/25) and (24/31),
s.
Free D alg (Columns 20/25)
Ent*r the date that the activity began in the format MMDDYY including leading zeros (e.g..
010151, 1001811.
If out-of-office direct effort uas involved. enter the date it began but do not include travel time.
If no out-of.-offt:0 offert, enter +he date in-office direct effort began.
b.
'e Data (Columns 26/31)
Enter the date that the activity ended in the format POOVV includino leading zeros (e.c.,
011681, 1006811.
If out-of-edfica direet effort vee ineelved. enter tha data
't endeo but do not include travel tino.
If n:t cut-of-O f' ice.
enter the date in-office effort e n d e d -.
158
.L.ip *.g.flp n De der-ed av (Column 32)
Check the appropriate her to indicate whe*her the ins:c:tien 3s nerformed by the regional office staff. a resioemt ins:ectre :" a i
performance appraisal team member, if an inspe:: son s :e*4:r e:
I 3 combination of any of the above pe* sons or grovos. toe 9 !"e principal inspector should prepare tLe 766/~66A forms, de s 0.':
indicate the unique modules inspectec and cutain s reco*
s ut*
- 'O' the appropriate cource.
NOTE:
Bor Cta"*
nas b;cn ad ed t:
J accomodate additional groups which perform asce:tions.
C des *:"
special inspection groups include (4) ccm.*ination ins:ect.:- : '.
regional staff and resieent inspecter (5) e-ergency peccaree-ess appraisal team. (6) construction insee: tion team. (7? hes! o -
,t ri
- appraisal team.
Other codes for nooitional seccial ins:c:
- - ; : :3 will be furnished by Headquarters.
a j
)
i
)
's; a
t'n g e
.v 149 G r e i n i r a *
- e n_C_n,rl.e.,,p,W,c,3 e n n / H,fL G_n.nel u.c_t.' n.D Art *vity iColumns 31/351
) orgsnizatior code will be a d a p t rid from the HPS code Appendis D.
..in p e er 0530 and will include the region. division and u r.i n c h.
a.
- faton (Column 33)
Enter the hPS IE HQ/ Region Identification code for the Regeon conducting the activity, whether ur not the facility listeo en Columns 2/14 is in that region.
b.
D6v8sien (Column 34)
Ior the division code, enter the MPS first o~ganizatiotial tiebdivision with IE HQ/ P ris i on code, c.
Granch (Column 35)
T,o r the branch code, enter the MPS second organizational subdivision uith IE HQ/ Region code.
1 1510 Denienal Aetien (Column 36) 1 i
For inspectio'ns and investigations.ccord the completing action by checking the appropriate boz.
Leave clank if report sent to HQ for action.
I 1511 Tvee ed Acti"itv Conducted (Colunns 37/3S)
'ucer nei t y one oor.
(See sections aw1-e63 for ce?snitions.)
1512 J n s e ee t i on/ f a va s t i c a t i on Fineines (Colven 38)
For inspections and investigations check only one bei to record the apprcpreate findings.
If there are no stens of violation. the sn r.*-t no should be checked af Clear (Pos 1).
1511 Terni Nuaber of vielitieas
=ad S=";stie, (Column 40/41) l Recoro the number of cited items of Violati:n snc Deviatier der the docket in the letter to the licensee.
1514 Endereement Cen4erence Wo.14 (Column GO)
Indicate by checking this bos whether on enterceavat :9 3e*ea: e
-35 part of the inspection.
If ti e pureose of :he a: ivity was 3:*
t enforcement the Type of Activity. Colunns 3 /30. Son C4 sa:v!: ce checked along with this box. if applicable.
1515 Pecert contain 2.7*0 ineca-at en (Colvnn 43)
'his column should be checked only when the*e is a test with:- !e port that has been marked as "erem0t" 1/ *./ 32
o-o Page 11 1516 Letter er eerort Tewnsmittw1 Date tColumns 44/55)
The Report Transmittal Cate must be greater than or equal to the To Date (Columns 26/31).
a.
URC Form 591 or eeninnat totte-Igipf4 (Columns 44/49)
Enter the date that the letter or Form 591 was sent to the licensee by the regional office in the format MMODYY incivuing leading zeros (e.g..
020181, 1101813.
b.
ponert sent te Ho 4ne Action (Columns 50/55)
Report Sent to Headquarters for Action - Vo not enter any information in this column unless the report is sent to Headquarters for enforcement action or, for an,incuiry.
Enter the date in the format MtlDDYY including leading zeros-(e.g..
0201813.
0535-16 PREPARING MODULE DATA The following programs are currently modularized and the appropriate module numbers should be used for reporting purposes instead of dummy module numbers.
MC-2500 Reactor Inspection Program
-2510 Light Water Reactors
-2520 HTGR
-2540 Pesearch Reactors (Effective 01/01/77)
MC-2600 Fuel Cycle Facility Inspection Program
-2610 Reprocessing Facilities
-2620 Plutonium Facilities
-2640 Uranium Facilities
-2650 Or-4 rnnuersion Encilities
-2660 Uranium Mills
-2670 Fuel Peceiving & Storage Facility
-2680 Fuel Facility Safeguards Inspection program MC-2700 Licenset Contractor & Vendor Irspecticn Pecgrae
-2710 Architect Engineer (AE)/ Nuclear Steam System Su:plie-(NSSS) Inspection Program
-2720 Reactive Inspection Program
-2730 Independent Suppliers
-2740 Third Party Inspection Organizctiens MC-2000 Materials inspection Program
-2020 Processors and Distributors
-2330 Radiography
-2340 Waste Disposal
-2350 Industrial. Academic. Environme,tal. Source "a:er a; a: i'."
(other than fuel Cycle Facilitses c c.' c r e d by.O 2.7%
1**'+1' Other specieic licenses
-2360 Medical 4
-2870 Shipping Casks, Transportation
.. H r
__A
e t
kage id nort of the form has been developed to provide a vehicle for the e-
--.cing and collecticn
-f h rir data centerniac tha status of the icect'on, program as applied to each individual facility.
The dato en an Form NWC 766 Will be stored in the 766 file for future
-d
. ar c a and analysis.
foe noe le Information part of the form will also be used to relate ns! ceted items of veolation listed in enforcement correspondence to a so e tic procedure (moduleI or a programmatic function or activity (dummy module 2 os discussed in Enclosure C.
!~
att i n t. t a n c e s where violation is listed a module number must be tded en the form.
- se of this term will reovire that, for each inspection performed, I
the inspector record' What modules were inspected.
?
What mooules were completed.
c.
What modules were left open, d.
How much of each module has been (cumulative) inspected (%). and a.
How much time was spent.
4 Priority ranking of each Inspection Prncedure Du ne' code violation against modules which are intenced to in4cem the licensee of our programs. summarize inspection results (such as 307C2.
!'l703. 10300) or followup on actions or e v e r. t s for which violation 1 ve cnarged to an inspection module.
Indicate unsch nodule.
waa.
t6her ' lii n the three tyces specified above. Was in veclatien.
141 (gp De m asine The Pr. v i a inf:rmation portion of the Form NR" 766 provides For tha racnedina of information on each module insrected and relntes it the inspection trip and report.
For each moovie numoer entere n
the
'crm.
the status, the percent complete. and the professional staf'havrs empended are recorded.
A specific mndule must be listed on the '66 whenevea any t
-e 9as :te' espended on it during tne inspection.
The *recific data eleacnts present on the f: m see
!=
- e c-cle e: s:
f.llmor.:
162
- eeere Tvea B (Colonn 1)
.e "B"
should be entered in celunn one to.ncicate a mocu!* re:: ;
. '52
a e
Page 13 163 Decord Numbee (Columns 2/3)
The record number is the numerical sequence in uhich data is stored in the file and must be supplied by the M!S Coordinator.
164 Module Number (Columns 4/10)
The seven-digit number assigned to this inspection module.
The module number is composed of four parts:
Phase, fl a n ss a l Chapter.
Procedures, and Level of Effort, for a total of s?ven positions.
A.
f.h.a.La (Column 4)
A number from 0 to 7 indicating the phase of the module assigned by the Manual Chapter.
Phases 1 to 7 are LWR phases and Phase 0 is for dummy modules
- Dummy Module (see enclesure C, page 21)
Phase 0
=
Phase 1
=
Pre-CP Construction Phase 2
=
Pre-Operation Phase 3
=
Startup and Pouer Ascension Phase 4
=
Phase 5
=
Operation Decommission Phase 6
=
fla j o r Modification Work Phase 7
=
B.
dynual chneter/pree-dure N u m q,te (Columns 5/10)
The five digit number from the 1&E Manual which identifies the, discrete inspection manual chapter and proceduro being documented.
The one alpha character corresponding to Level of Effort the A,
B, or C level of effort to be espended.
This may not be applicable for various modules.
NOTE:
A module number may be entered on the individual 766 form only once.
The recording of a module numoer more than once is not valid escept in the case of module number 927018.
C.
Frieritv (Column 12)
For the construction program enter the orierity ranking 4 on MC 2512 using orabic syncols (either 1-2.
or 3).
For all other programs lesve blank.
j D.
Dirart inneeetien E43ert in Cta43heurs Eveeacee *"i t Insnaction (Columns 13/15)
For each module listed indicate the total professional staffhours of direct inspect on ef3ert e penced on ::*0let':n of the line items in this nedule OLeing the period
- vere
- ^
this report by all inspectors wne eseticipateo.
Cn;/ a - C '. E
' / '. / : 2 1
i e
e i
Page 14 HOURS are recorded.
The system does not accept tenths of hours.
Therefore, for any inspection involving two or more modules it may be necessary to show 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> for some modules on the 766 form so as not to distort the distribution eF time spent on modules or to inflate the total time actually spent on the Inspection.
For examplee if the total site time is in j
the order of 1 or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. the 15 e r 20 minutes spent on 1
30703 should not be rounded up to I hour.
A distorted picture f
of the inspection could result.
The following guidance is suggested to prevent introduction of misleading site (Direct inspection Effort) hours into the 766 system.
Record 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> against 30703 if the total man-hours of direct inspection effort for an inspection is less than (a) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or (b) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and less than 1/2 hour is spent on 30703.
The total inspection time should be recordec against the major inspection module used.
The regional staff will have to emercise judgement on other vafiations. such as use of 9xxxx medules and dLfferent combinations of program inspection and exit interview timee in order to maintain a correct balonce of recording time against modules so as not to erceed the total time actually spent conducting an inspection.
The only staffhours to be reported here tre as follows:
1.
Out of Office Inspection Effort, which includes onsite and offsite inspection, effort, and 2.
In Office Inspection Effort, which includes the inspec-tion of licensee records; fact-gathering activities which are more efficiently performed in the office than at the licensee's facilityi and an extension of the field inspection processe but performed in the office.
Only the time actually reavired to complete inspection of the line items contained within a specific module should be attributed to that module.
In the event problems or potential problems are icentified during the completion of a module, the time euponded in resolving the oroblem should be attributed to the appropriate follow-up module 92701B.
NOTE:
Direct inspection effort 1 f'_ s not iaelede preparation for an inspections documentatten Of ano reocrting t r' e results of the inspectio.; preparation of regular an:
enforcement correspondence; or trovel to an: fr:. the site.
E.
Perceatnoe Co-eleted to Date (Colurns 16/13)
For each module listed. the percen- :: :!ete is a judge *est on the part of the inspector reflecting the amount cf eidort expended as a percent of the tctal effort to be eventvolly required as defined by the Manual.
(In instances une e all the individual line items of a procedure cannot ce oc::--lis*ec because of the nonexistence of referenced systems, c:-n:aeets.
1/ U82
o Page 15 reports, etc., then the percent of total effort should be be based on what is applicable at that facility.)
The percent should be rounded in multiples of 10. and must be cumulative to date.
For ezample, if a module was reported 70% complete the first time it was inspected and the remaining 30% was completed on the secono inspection. then the module status form documenting the second insoection i.e.,
the actual total percent would show a total of 100%,
complete at the time of the report.
100% is the maximum entry.
Computation for Determining % Complete Total 5taffhours Expended Through Current Inspection, over the total estimated staffhours needed to complete module, times 100 equals the percent.
NOTE:
Do not enter Percent Complete or Status on Form 766 i
for Module.30703, modules in the 9:XXX. 93XXX and 96XXX series, or modules designated "When req 0 ired".
F.
Status (Column 19)
For each module listed, indicate the appropriate status code, as follows:
Open:
Leave open, this module is to be inspected Blank =
further on a subsequent inspection.
C = Closed:
If all line itens for an inscection have been inspected. then the module should be closec.
(Note:
there are other situations when a modvie should be closed.)
Reopen and Leave Open:
This code is used in cases where L =
The inspector is able to do additional work on a previously c!? sod module and now wants it left open indefinitely.
By v_
49 the ' code, the module is recpened and left cpen liuefiniteiy or until the inspector decides to close it I
later.
P = Reopen for this Transaction Only:
This code is used in a manner similar to the L code above, escept that a eccule closed previously will be reopened to receive accitiemal staffhours or a revised percent conplete esti-ate #ce t'5 one cccasion only, and will then to clesec.
I
=u L
a
o ll C iN G.
Nedules ranvirinq f.ql_lp.wsp. (Columns 20/26)
When a
problem or potential problem is identified by the inspector during the completion of a modulee tne time empended in resolving the problem nr potential probiem shoulo j
be attributed to Module 92701D (Follow-up on Insrector Identified Problem).
The m o'd u l being inspected when the problem nr potential problem is idtntified,should be recoroec in the column " Module Req. Fullow-up".
Each module renuering follow-up should be documented on c separate line on the module information portion of the 766 form.
H.
Guidance for use of Module 92701 Any time spent following up un what are normally referred c
as " unresolved items", or other time spent on resolving j
problems identified during accomplishment of a specific module should be reported under 92701 with the appropriate module listed as recuiring follow-up.
As an examplo, puring the review of lon books specified in 71710 - Review of riant operations.'the inspector may infer that the number of inoperable control rods exceeds.the l i m i '. specified in technical specifications.
The' time empended for follow-up insoection effort on the control rod problem is reported und'er 92701 with 71710 listed on form 766 as the moovie requiring follow-up.
I In. contrast. a situation may arise which is totally unrelated to the module (s) being inspected.
As En example, i
i if during the conduct of the inspection procedure 't7:J..i a explosion occurred in the OFF-GAS "ystem at a GilR facilitv.
the inspection time expended for the follow-up or this unplanned event will be charged agcinst 93701 - follow-up :n significant event that occurs curing inspection.
Conowc: af the insoec-tion procedure 71710 in no way leads to tno identification of the " problem".
. '. i 3 2 v
e' Page 17 1.
Guidance der use of " Independent Insnectinn Effect" R e, g,n e t o q under Module 92704 As stated in Section III of the procedures for this modvic.
the defined inspection requirements contained in the manual are to constitute 80% rf the allotted onsite inspection effort.
Twenty percent of the inspection effort is availabic to the inspector for activit'.es outside the defined inspection progran.
"Out s i d e" '.he d e f i ne d inspection program means that the activity esceeds the frequency, scope, sample size, etc..
prescribed in o t P. e r modules.
For example if the inspector examines aspects of core' physics, fire protection, training welding, modifications, etc., which are not included in the inspection procedures, the time would be charged against module 92706.. Likewise, any violation identified by the inspector during the additional inspection effort would be coded against Module 92706.
0535-17 PREPARING FORM NRC - 766A (Columns 27/28) 171 Identi+ vino information The docket /11 cense. Report, Secuence and the module number must be entered on the form 766A. These elements are the link between the 766 form and the 766A form.
(The 766A form is to be used gnl1 when a deviation or violation occurs.)
172 Vieistion severity er Deviation 746A (Column 27) l A. Vielstion Seveeltv (Column 27)
Enter the severity level assigned to the violation iten fcr i
those violations identified in the enforcement letter ca en f
a Form NRC 591.
See 45RF66754 for information on the coding j
of severity levels.
Where a modular inspection program tc in effect, i.e.,
inspection procedures have been cefined in the IE Manual, the severity should be entered on the line with the corresponding Module that was being inspected at the time the violation was uncovered.
I If inspection procedures have not.s e e n established (see Section 0535-16 for modularized progeans), a du-y -coule must be entored (See Enclosure C for the medvie mv-be* end instructions).
Enter any violation severity relattag r:
dummy module.
)
L US2 F
P a ni c to B.
Deviation (Column 27)
When a licensee does not conform to commitments to the Commission, or to the provisions of guides, codes and standards or to acceptable practices which were approved by the Commission and made available to the licensee ano such lack of conformity does not constitute a violation, then it is referred to as a " deviation".
A "D"
is entered in-Column 27 whenever a deviation has been found.
The actual deviation code should be placed in the first five positions 0 8 the deviation teut.
(See Section 174 Teut. for more details about the testual information.)
173 site e e t_n,13 d ( C o l u m n 28)
In some instances. during an inspection trip at a multi-unit power reactor station, o specific item of violation or devigtion is found that ices lead to a r.itation against more than one unit at that station.
When the above situation occurs:
1.
Enter "S"
in the box entitled Site Related (beginning with Box A) on 766A form for one Unit onl /.
2.
On each additional unit at that same site, enter "A"
in the succeeding bones entitled Site Related.
)
NOTE:
F. ar n_Le i During on inspection at the Dresden site a violation or rio v i a t i on is identified which is charged to units 1.
2.
3.
On the form 766A for Dresden i enter "S"
in box A,
entitled Site Related.
On the form 766A for Dresden 2 enter "A"
in boa B.
entitled Site Related.
On the form 766A for Dresden 3 enter "A"
in box C.
entitlec Site Related.
NOTE:
Evn= ele 2.
During an inspection at the Harr s s!
e.
a violation or deviation is identified w: n i c h is coareed te 9: ts 2 and 3, but not 1 and 4 t
. ' 17 a
r
Paqc 19 On the form 766A for Harris 2 enter "S"
in bon A.
entitled Site Related.
On the form 766A for Harris 3 enter "A"
in bos B4 entitled Site Pelated.
174 Tant (Columns 2/51)
For each violation or deviation begin the tent with the s t a t e meis t
" Contrary To" and sencify the specific guide or standard that the text refers.
Provisions have been made for capturino up to 0400 characters of teut of violstion and deviation items.
Should the actual test of the item. in oppearing in either the enforcement
~
letter or the report details, exceed this n u m b ~e r it will be neerssary to paraphrase the item to kocp within 2400 characters.
Notheng precludes paraphrasing all such items, but it should be recognized that the wording will be used verbatim as the input to the Enforcement Status of the " Rainbow" books.
a.
Violation Each violation must te described in detail to include the applicable requirement and the factual information t h a,t demonstrates that a violation e isted.
(The recuirencnt Should be referenced, net described.
If cited. this item l
should appear essentially as it appeared in the enfor cment letter to the licensee.
The test should be develeped in accordance with the instructions in Chapter 1000.
If the violation is ascociated with a NRC Form 591, the test is to be the statement of the violation as it a p n e n c e, in the HRC Forn 591.
For exneple, the text of a estation for failure to post a radiation crea would be " Rooms cr areas were not procerly posted to indicate the presence cf a radiation area."
b.
Deviition Each ceviation must be described in detail to incluce te item not complied with and the factual in4cr ation that demonstrates that a deviation euistco.
The first dioc positions in the teat should centain the ocvisti:n : :" a.
general. the applicable ccemitment, cecc. guice. sic"(.src :"
e occeptable practics shoulo be re cren=ac. -:: : 2 s c e '., e c.
Usually. the reference must be specif c.
19 5:*e C25:5. i-veder to clarify the opplicabic c --i:-en:.
- 2
.::e e' standard, it may be necessary to prev +:c s "
al :ss: :::;--
in addicion to the reference.
This ite* sncs.c 2 0:Jr essentially as it appeared in the !ctter to the Irce1:ee.
The text should be deveicoed in a::: eVance w i t ** :ne instructions in Chapter 1000. Manual 0 a::e- : 05. 52:t :-
1005.25.
- a O
__.._._________._d
Page 20 0535-80 PREPARING FORMS NRC 766 and 766A FOR 766 MASTER FILE CHANGES 801 Comeral Once a record has been created on the 766 Master File, i.e.,
t5e Form 766 and Form 766A have been processed and the datn entered into the computer system. modifications to the record for that inspection.
inquiry or investigation are made through the use of the same forms (NRC766. 766A) used to originally create the record.
302
- eseensibilitv As the regions accept the responsibility for their own 766 data entry and p r e -a d i t processing they will also be responsible for the accuracy of the 766 Mastor File.
This will require the use of Forms NRC 766 and 766A to delete and modify the 766 Master File dato.
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(Continust6on)
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U.S NUCLE AR REQuLAf ont cCMM45iC m
__---__-______a
a ENCLOSURE C (REVISION !!)
DUMMY MODULES (PROCEDURE) NUMBERS Use of these modules. In the absence of an appropriate procedure number for those programs currently modularized, is required for coch inspection and investigation (see Section 171 for a list of modularized programs).
Tbn purpnse of the dummy module number is to provide a record of ti e direct inspection effort and related violation associated w i t ',e those specafic (or geners!) programmatic functions or activities conducted by IE which are not presently modularized.
The modules are to be used foa all activities whether clear or not clear.
For each dummy modulo entered on the 766 Forn, record the hours of direct inspection effort and any violation according to the instructions u rid e r MC 0535 Sections 163.
The use of these modules will enable the field inspection staff to further d e fi n e the nature of the various activitics.
The Phase in the Module Number Inspected field must always contain a zero (0) when a "dum.iy" module number is being used, li$t 04 "OUmmy" Medujeg Module Idanti*iention
@Jyle Number fImelodinn P h ayf_)
099001 Abnormal Occurrence 0?9000 Emergency Planning Environmental Protection 09?003 Geners! Ilcalth a Ssfety 0?9004 Material Control & A:c't Oa?005 099006 t4u c l e a r Safety 0*9007 Plant Security Radiological Protection 099003 099009 Reactor Construction 0?9010 keactor Safety 00701i francoortatien L b' R ' s Unoer Construction (to be deleted) 090012 099013 Li!R 's Being Decommissioned 09701c Investigations 3 Mile Island Inspections Fer Sandia Study 0?9015 Test i Startup (Region II) 0290t6
^2901" Venoor Inspection Power Ascension Phase (Region IV) 0'90;S HfGR Feaaiuility Study of Independent NDE 0: 20':
Construction Deficiency Reportsng - 50.55(E) 02: 000 Systematic Assessment of Licensee Performance 0;:00t
. '. > i."
1 I
Enclosure C For m o d u l a r Z '.' O programs ( s e. a Section
'*1
- er a l i a. t of nodular i zed nrograms) use the applicab!c pin"edure-(modutos)
- hat st a v e been established in the 9000 9300 ind 9 00 chapters for 311 types of reportable. sinnr o u t i nc a sic unclenned activities.
For all other p-ogr:-c that are not todularized use the " d u e. n y " modules.
Use of these cedes is on an interim basis pending incorporation of inspection requirements into the IE manual.
2
. '. 1:
MC 0535 ENCLOSURE D CODE OF DEVIATIONS CODE NAME OF COMMITMENT, CUIDE, CODE, OR STANDARD
-COMM11MENTS=
PSAR PRELIMINARY SAFETY ANALYSIS RIPORT FSAR FINAL SAFETY ANALYS15 REPORT APPL APPL.1 CAT 10N CVTR VENDOR TOPICAL REPORT OCOM OTHF.R COMMITMENTS TO NRC(NRR, NMSS, AND 1&E)
CUIDES
RECCD REGULATORY GUIDE NO.
STANDARDS OR CODES
ANSI AMERICAN NATIONAL STANDARDS INST 11TTE ASME AMERICAN SOCIETY OF MECHANICAL F.NCINEERS ASNT AMERICAN SOCIETY FOR NONDESTRUCTIVE TESTINC ANS N'.ERICAN STCLEAR SOCIETY ASiH AMERICAN SOCIETY FOR TESTING AND MATERIALS IEEE INSTITUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS ASA AMERICAN STANDARDS ASSOCIATION ACI AMERICAN CONCRETE LNSTITUTE NFPA NATIONAL FIRE PROTECTION ASSOCIATION EPA ENVIR0hHES"IAL PROTECTICS C MINISTRATION ND'A MATIONAL ELECTRICAL MANUTACTL'PIRS ASSOCIATION Ak'S AMERICAN k*ELDING ASSOCIATION ASCE AMERICAN SOCIETY OF CIVIL ESCINEERS ANIM ASSOCIATION OF hTCLE.AA INST?c'.ENT MANUFACIVRERS ESSA ENVIR0hMENTAL SCIENCE SERV!CES CMINISTPAT!CN NAS NATIONAL ACADEMY OF SCIC;CES NES NATIONAL BURIAU OF STA.";APas INMM INSTITUTE OF STCLEAR MATIRIALS wASA~I.SS"-
ISA INSTRUMINT SOCIE'"Y OF Aw. ERICA NCRP NATIONAL COUNCIL CN FADI ATICN PRCTE;; ION g.-)
FASURDd.ENT t
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NC 0535 ENCLOSURE D l
l OCMA OCCUPATIONAL SATETT AND EZALTH ADMINISTRATION l
USAS USA STANDARD OSOC OTHER STANDARDS OR CODES (SEE NSIC 112 OR LATER EDITION) l-
ACCEPTABLE PRACTICE
CAPI GENERALLY ACCEPTABLE PRACTICES IN THE INDUSTRY l
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MC 0535 Enclosure E List of HQS Action Codes Action Code No action required 01 Letter issued to licensee 02 Part 2 Notice Issued to Licensee 03 04 '
Order issued Proposed Civil Penalty issued 05 Referred to licensing for resolution 06 Referred to Region to close out 07 Other rossen 08 0535E-1 c/25/--
9
e
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ENCLOSURZ T (RZ7:5:0N
)
DCMMY MODULIS (PROCCURE) NUM3ERS Use of these modules, in the absence of an appropriate procedure sunbar for those programs currently secularized, is required for each inspec-tion and investigation (see Section 171 for a list of modularized programs).
The purpose of the duary module number is to provide a record of the direct inspection affert and related itsas of noncompliance associated with those specific (or general) programmatic functions or activities conducted by II which are not presently modularized.
The modules are to be used for all activities whether clear and not clear. For each dummy.aodule entered on the 766 Form, record the hours of direct inspection effort and any noncompliance according to the instructions under MC 0535 Sections 174 and 162 respectively. The use of these modules will enable the field inspection staff to further define the nature of the various activities included in an inspection, and the corresponding inspection report, as shown in Block T of Tors NRC 766. For axample a routine inspection of a fuel facility may have included a review of ' nuclear safety. radiological protection and plant security.
Only box 02 (Routine - No.Ise) of Block T on Tors NRC 766 can be checked; however, recording of various " dummy" modules on side 2 of the form under Module Tracking Information, will enable the region to show the varicus major inspection elements included in this report. The Phase in the Module Number Inspected field must always contain a zero (0) when a
" dummy" module number is being used.
List o f "*h:=mv" Medule s Medule
- identification Medule Nember I:ngladin ?hste' Abnormal Octurrence 099001 Emergency Planning 099002 Environmental Frutection 099003 General Health & Safety 099004 Material Control & Ace't 099005 Nuclear Safety 099006 099007 Plant Securacy Radiological Protection 299008 Reactor Construction 099009 Reactor Safety 099010 099011 Transportation LWR's Under Construction (to be deletec) 09901:
LWR's Seing Dec:nztssioned 099013 099014 Investigations 3 Mile Island !nspectiens per Sandia 5tudy 099015 Test & Startup (Regien ::)
099016 Vendor Inspection 099017 HTCR - Power Ascensi:n Phase (Regien !*.*:
099018 Tessibility Study of Independent N*0 E 099019 0535F.;
": :L ~~
V MC 0533 ENCI05t*1Z T (RI*'ISION II)
For modularized programs (see Section 171 for a list of modularized programs) use the applicable procedures (nodules) that have been established in the 9200, 9300 and 9400 chapters for all types of reportable, nonroutine and unplanned activities.
For all other programs that are not sodularized use the
" dummy" modules.
Use of these codes is on an interim basis pending incorporation of inspection requirements into the II anual.
u l
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1.
APPENDIX 6 U.S NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEM!NT INSPECTION AND ENOFRCEMENT MANUAL Chapter 0500 MC 0537 - QUALITY ASSURANCE PROGRAM FOR THE 766 COMPUTER SYSTEM TA8LE OF CONTENTS Page 0537-01 PURPOSE 1
0537-02 BACKGROUND 1
0537-03 POLICY 1
0537-04 STANDAR0 1
0537-05 RESPONSIBILITIES 2
-051 Regional Directors 2
-052 Executive Office for Operations support 3
-053 Executive Office for Management and Analysis 3
0537-06 DEFINITIONS 3
-061 Audit 3
-062 Corrective Action 3
-063 Quality Assurance 3
-064 Quality Control 4
-065 Verification 4
-066 Inspection Report 4
-067 Investigation Report 4
0537-07 GENERAL INFORMATION 4
0537-08 STATISTICAL DATA SHEET AND SUPPLEMENT 5
q l
0537-09 NRC 766 - SIDE 1 AUDIT 5
i
-091 Block A - Docket NumDer or Licensee Number
]
(By Porcuct) 5 j
-092 Block B - Report Number 5
1
-093 Block C - From Date 5
-094 Block 0 - To Date 5
-095 Block E - Region Conduc'.io9 Activity 6
-096 Block F - Inspection Performed Ey 6
-097 Block H - Accounced/ Unannounced 5
-098 81ock J - Inscection/ Investigation Notification 6
-099 Block K - Inspection / Investigation Findings s
' I. ' 3 ". ' ~ ~
I 1
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U. $. NUCLEAR REGULATORf COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT INSPECTION ANC t W RCEMENT MANUAL CHAPTER 0500 MC 0537 QUALITY ASSURANCE PROGRAM FOR THE 766 COMPUTER SYSTEM 0537-01 PURPOSE This chapter requires establishment of a formal program in each Regional Office and in Headquarters to assure that important data in the 766 Computer System is as accurate as possible.
0537-02 BACKGROUND The 766 Computer System contains a variety of verbal and numerical data about inspection activity, enforcement actions, the results of inspections and investigations, the status of the routine inspection program at each facility and the cost in manhours of performing the routine and reactive inspection procedures. The data is utilized by NRC program offices, the Office of Inspector and Auditor, the General Accounting Office and by increasing numbers of licensees and their consultants. It forms the basis for answers to questions that NRC receives from Congress, the Commission, State governors, interveners, and other interested parties. These are official agency answers. They must be as accurate as practical so that the receivicg parties can rely on their validity.
Further, the data is used in the analysis of IE programs and to support budget requests.
There is a ready means of checking the accuracy of the data if an outsice party wants to do 50.
For example, it is a relatively simple matter to check the data about a licensee's record of noncompliance with the reports anc letters NRC has sent that licensee and placed in the Public Document Room. If tnese two sources of data do not agree, it would be a source of embarrassment as a minimum, and depending on the situation, could seriously erode the credibility of the agency. The parties outside of NRC cartainly have the right to excect that NRC would have the types of cata we collect in our 766 Computer System and that it would be as accurate as practical.
0537-03 POLICY Each Regional Office and Headquarters will establish and carry out a program to assure the accuracy of the inspection, investigation and enforcement data -nich it enters and maintains on tne 766 Computer System. The incividual p ograms must conform to the standard that is given in this instruction.
0537-04 STANDARD The Regional quality assurance program shall consist of these three stews.9:-
must ce taken before releasing the cata to the Pr0gaam Management Infer.?a**:.a Branch for entry into the master computer file.
0537-1
- ^ 2; 7 1
3 C.
Runr.ing all required computer edits.
D.
Cor.recting all errors in a prompt manner.
E, Having data available to Headquarters for system update within seven (7) working days after an inspection report y iss'ued.
052 Executive Officer for Operations Support A.
Verifying on a monthly basis the accuracy of data about Headquarters enforcement actions on the 766 system.
B.
Reporting any errors to tne Executive Officer ~for Management and Analysis.
053 Executive Officer for Maracement ar.d Analysis Updateof766filewithintdo(2)workingdaysof A.notification by Region of data availability.
B.
Running a quality aserance statistical sample audit and reporting results.
C.
Notifying the Region of possible missing inspection report.
D.
Correcting errors wnich Headquarters has identified.
0537-06 DEFINITIONS 061 Audit. A planned and documented e.ctivity performed to determine ey examination or evaluation of 766 and 766-5 forms the adequacy (accuracy end completeness) of and compliance with established procedures, instructions and other applicable documents, and the effectiveness of implementation.
062 Corrective Action. Measures taken to rectify conditions adverse to quality anc where necessary, to preclude repetition, 063 Quality Assurance. All those planned and systematic actions necessary to provice assurance that the 766 and 766-5 data is valic.
j 0537-3
'." T. ~-;
f
'1 t
1 y]
j h
/
i) y,,,
.s.
. ),.'
'\\
f~'
.t and prior to be'd base update, the data is to be compared with the original 766 and 766-$ fo vs to insure thar no errors have been introduced durino keyboarding.
Y!
j 0537-08 STNISTICALDATASHEETANDSUPPLEMENT
/'
u In order to condutt a qualit). meck it is necessary that one statistical 1 ta j
sheet (form 766) be completeo for each unit or license inspect 6d'during an J
inspection and that a supplemental data sheet (form 766-S) be prepared for each item of noncompliance and deiriation. If one or both of these forms are missing and not part of the review materials, notify the prfrripel inspector of the fact. A review should not, proceed entf1, all materials are availabic.
0537-09 NRC 766 - SIDE 1 AUDIT
/
f
'091 Block A - Docket Number or License Number (Sy4Nduci.)
i Validate that the DOCKET NUMBER is the same as the C,ocket Number contained on the Inspertic% Report Cover Page. For t'aulti-u1it i
facility compare all dodet numeers. This applies tu' other than
/
Part 30 licensees. If the license number is coded instead df the t
docket number, dich asy be the case for material licensees other j
than priccity J,jverify that it matches the license number two on the Inspection Report Ccker Page.
(<
'~
i l ;.., '
)
092 Block B - #ecort NMtber., t '
1 Validate triat the Res.ori Numoer is the same as the Repst Number contained in the Inspection Ra m t Cover iage. For a multi unit f acility compare all report nuet,ers since they may dif fer from unit V
tc unit.
C y
i 6
093 Block C - From Date Validate the dete; ents/ red on the form against the date on whic't the
/
activity began which is found on the Inspection Repert Cover Page.
\\
- l l
,A 094 Block 0 - To On g i
Validste the dato sintered on tne form against the dire the activit/
]
ended which is found on the Ir60ecti m Report Cover Page.
(
NOTE, )Regarding blocks C & U.
If the ef fort began ant eded I
. /
/ r.n ne sant date, tnb cate is entered in both C enc C.
/
1 C527-5 1
~
1[ ',' I h i
}
l
~
j f
k
, f..,
hY/
on the back of the NRC 766 form as well as the number of NRC 766-5 t
forms completed for cited itees of noncompliance.
~
0911 Block N - Number of Deviation items in letter to Licensee-s Count the number of deviations identified in the letter to the licensee and verify that it matches the number entered in Stock N.
Count only those deviations related to the docket in Question.
This number must correspond to the number of NRC 766-5 forms completed for items of deviation.
0912 Block 0 - Number of Licensee Events Reviewed Onsite This Inscection If. " Reportable Events" are reviewed onsite they may be enumerated in the report. If available, count the number and validate it against the number entered in Block O.
Count only those related to the cocket in question.
n 0913 Block Q-Contains 2.7900 Information This block should be checked only,when there is text within the report that has been marked as "exempi.".
If this block is checked the report should also be stamped that it contains 2.7900 data. Validate that the block and the report are consistent in their designations.
NOTE: Classified data is not allowed on the 766 data base.
)
^
'0914 Block R - Reoional Office Letter or Reecrt Transmittal Date for Inc.pection or Investigation l
The Report Transmittal Date (Block R) must be greater than or egual i
mgc j to the "T0" date (61ock D) fr jj a.
591 or Letter Issue
/A/\\
Validate the date entered on the form vs. the date the letter or Form 591 was sent to the Licensee.
NOTE: The other fields in this block cannot be valicated.
0537-10 NRC 766 - SIDE 2 ACOIT 101 Manhours Excenced This Recort Add up the total manhours of direct inspection effer*. ev:e-ee '*c*
the Side 2 of the 766 form and comcAre it with the nu cer cf
.ce's 0537-7
- 2 '3 UT?
.g.
If box A of Block A is checked the three character noncompliance code derived from the " Catalog for Coding Items of Noncompliance (enclosure D) was used. Verify that the code is a valid code and the same code is used on side 2 of the 766 form. If box C of Block A is checked verify the 3 to 5 character identifying code against either Section I, Part B " Vendor Deviation Codes" Enclosure D, or the list of commitments, codes, guides, standards or acceptable practices shown in the " Code of Deviations" Enclosure C, all of MC-0535. The Cause, Procedure and Severity are to be used only for specific items of noncompliance but not deviations.
Cause - The cause code must be alphabetic and one of the codes listed in Section II, Enclosure D, MC-0535.
Procedure - The procedure code must be alphabetic and one of the codes listeo in Section III, Enclosure D, MC-0535.
Severity - Verify that the severity code is the same code as that used on tne 766 form Side 2 for the specific item of noncompliance.
114 Block C - Module Number The module number must match against the associated module number from the 766 form Side 2.
115 Block G - Additional Units If a noncompliance is cited against more than one unit at a multi-unit facility it may be so stated in the Sum' mary Section. Determine if the field is coded according to the rules stated in Section 208, MC-0535.
116 Block 1 - Text Review the text on the form and the text in the body of the inspection j
report to determine if they deal with the same subject matter anc con-1 form to the rules as stated in Section 210 MC-0535. The text for security noncompliance will not be the same as in the inspection report.
0537-12 Reports Statistics must be kept for each set of 70% and 766-5 forms auciteo.
These statistics should include cata 0.
Incorrect or no entry in eacn of the audited blocks Severity coce on 766 coesn't agree -ith that on 766-5 0537-9 12'3109
_.__-__-_________-___-__-__A
APPENDIX 7
'c, UNITED STATES I
NUCLEAR REGULATORY COMMISSION m
wasmwovow, o. c.sessa SPOT /
e...*
January 2,1987 MEMORANDUM FOR: Dennis F. Kirsch, Director Division of Reactor Safety and Projects Region V FROM:
James G. Partlow, Director Division of Inspection Programs Dffice of Inspection and Enforcement
$UBJECT:
PERIODIC REPORT ON REGIONAL IMPLEMENTATION OF THE 2515 PROGRAM This memorandum forwards the " Periodic Report on Regional Implementation of the 2515 Program." The report presents a compilation of 766 inspection data for all Region V operating units and SALP evaluation data for selected operating units.
It provides the ability to monitor changes in inspection resource allocation from one SALP evaluation period to the next.
The report consists of 3 enclosures. Enclosure 1. Average Inspection Hours, provides regional and national per unit averages of the inspection hours reported during the most recent SALP evaluation period. In addition, identifies the relative contributions of the ir.spection effort in each SALP functional area., Inspection Effort Per Dperating Site, provides data derived from the 766 system. It is an alphabetical listing, by site, that details reported inspection hours for each inspection procedure for the region. To provide a historical perspective, inspection hours are reported for the most recent and the two previous SALP evaluation periods., Inspection Resource Allocation for. Plants of Interest, lists inspection effort and SALP ratings for selected operating sites. The sites reported are those two in the region with the highest and two with the lowest combined SALP ratings in the operations, maintenance, and surveillance functional areas. Selection is based on the latest SALP reports.
The report represents the first use of infomation assembled in a new 2515 inspection effort /SALP dstabase. Technical notes and a list of effective procedures are included with Enclosure 2 to provide background information to assist in interpretation of the reported data.
This report is intended to provide insight into regional inspection effort on a specific operating unit level. Variations in the data may be the result of several factors, including:
(1) inspection procedure perfomance frequency; (2) variations in the length of SALP evaluation periods; (3) inaccuracies in 766 dna reporting; and (4) inspection effort adjustments dictated by chances ir, the level of licensee performance. Since valid analysis of this date w:Lic
Dennis F. Kirsch recuire consideration of the above as well as other factors such as the number of residents per unit, etc.; this report does not present conclusions on the region's effectiveness in implementing the 2515 inspection program. Rather, it is intended as a tool for use by IE and region management to facilitate more efficient use of limited inspection resources.
Your corrents on format and content changes which would increase the usefulness of the report are requested within 6 weeks of the date of this memorandum. If there are any questions, your representative should contact Michael Johnson on FTS 492-4808.
N&
Jame:
G. Partlow, Director Divi:.fon of Inspection Programs Office of Inspection and Enforcement
Enclosures:
Periodic Report on Regional Implementation of 2515 Program cc w/ enclosure:
J. Taylor, IE R. Starosteckt. IE F. Hebdon, AE00 W. Brach EDO J. Blaha, IE E. Jordon, IE B. Grimes, IE R. Scarano, RV B. Faulkenberry, RV i
ENCLOSURE 1 AVERAGE INSPECTION HOURS PER UNIT
- REGION 5 Region Nationwin Average
% of Average
% of Per Unit Total Hours Per Unit Total Hours OPS 1323.5 41.4 745.4 30.1 RADCON 169.3 5.3 182.3 7.4 MAINT 201.0 6.3 186.0 7.5 SURV 224.4 7.0 247.1 10.0 FP 27.5 0.9 28.6 1.2 EP 150.7 4.7 191.7 7.7 SEC 79.5 2.5 73.5 3.0 OUTG 214.1 6.7 169.0 6.8 QP 758.8 23.8 612.5 24.8 LIC 3.9 0.1 1.6 0.1 TRG 40.8 1.3 35.9 1.5 TOTAL 3193.5 2473.6 DAYS 440.0 465.5 IN RATING PERIOD l
- Data re:orted is for the latest SALP report period.
1-1
a
~
l ENCLOSURE 2 INSPECTION EFFORT PER OPERATING SITE This enclosure provides an alphabetical listing, by site, that details rece-ted inspection hours for each inspection procedure. The following technical notes and the List of Effective Procedures assist in data interpretation.
3.
- SALP rating period - not defined " is intended to indicate that since the database is keyed to operating SALP evaluation periods, inspection hours are not reported prior to the issuance of the site's first operating SALP.
2.
Only those inspection procedures which were effective during the SALP evaluation period under consideration were downloaded from the 766 systen.
3.
Zeros reported for inspection procedures during earlier SALP evaluation periods may indicate procedures that became effective too late in the period to have been implemented.
4.
Inspection procedures for which no 766 system entry was made during the period under consideration are not listed. Similarly, functional areas are not listed if no inspection procedures in that functional area were entered in the 766 system.
5.
Inspection procedures 30702, 30703, 94600, and 94703 make up the Inspector Meetings section of the 2515 inspection program and do not directly correlate with any SALP functional area. For this reason, hours expended on these procedures are not included in this report.
l 2-1
LIST OF EFFECTIVE PROCEDURES Initial Cancellation Initial Cancellation Module issue Date Date' Module issue Date Date 1
30700 07/01/77 09/13/83 60710 10/01/80 30702 07/01/77 61700 01/01/82 30703 01/01/82 61701 10/01/80 35001 07/01/86 61702 10/01/80 1
35030 01/01/77 04/01/83 61703 10/01/80 05/12/86 35701 01/01/82 61704 10/01/80 04/12/86 35750 08/23/85 61705 10/01/80 35751 01/01/79 02/12/86 61706 10/01/80 36100 04/01/83 61707 10/01/80 36700 01/01/82 61708 10/01/80 36701 01/01/79 09/13/83 61709 10/01/80 37700 01/01/82 61710 10/10/80 37701 10/01/80 61711 10/01/80 02/12/86 37702 01/01/79 61719 10/01/80 10/03/85 37703 01/01/79 61720 10/01/80 38700 08/15/82 09/13/83 61721 08/15/81 09/13/83
+
38701 01/01/79 61724 10/01/7.9 08/23/85 38702 01/01/79 61725 04/01/80 39701 01/01/79 61726 10/01/80 39702 10/01/79 61728 01/01/84 40700 08/15/81 61729 08/05/81 03/07/86 40701 01/01/79 62700 01/01/82 40702 04/01/80 62701 10/01/80 09/13/83 40703 01/01/79 62702 01/01/82 40704 01/01/82 62703 01/01/82 41400 05/23/85
'62704 07/11/85 41700 01/01/82 05/29/85 62705 07/11/85 41701 08/15/81 63700 10/01/80 10/03/85 42400 01/01/79 64703 08/15/81 02/12/86 42451 10/01/76 64704 08/15/81 42700 01/01/82 65051 01/01/83 50095 04/11/79 70307 10/01/79 54701 01/01/79 09/13/83 70313 04/01/76 10/03/85 55050 06/20/83 70323 08/15/75 55100 06/20/83 70370 04/01/77 55150 06/20/83 71707 01/01/82 56700 01/01/82 71708 08/15/81 12/27/82 57050 06/20/83 71709 08/15/81 12/27/82 57060 06/20/83 71710 12/27/82 57070 06/20/83 71711 10/01/80 57080 06/20/83 71714 01/01/82 57090 06/20/83 71715 06/25/84 57700 01/01/76 72700 01/01/81 60705 10/01/80 72701 10/01/80 2-2
)
1 LIST OF EFFECTIVE PROCEDURES Initial Cancellation Ini'.i al Cancellation Module issue Date Date Module issue Date Date 73051 10/01/80 81151 02/24/79 05/09/84 73052 10/01/80 81153 02/24/79 05/09/84
.73753 01/01/79 81155 02/24/79 05'/09/84 73755 01/01/79 81157 02/24/79 05/09/84 79501 05/23/85 81159 02/24/79 05/09/84 79502 05/23/85 81210 01/31/76 05/09/84 79701 08/06/85 81230 01/31/76 05/09/84 80521 01/01/84 81300 09/01/79 08/16/82 80721 01/01/84 81362 04/01/80 08/16/82 81018 05/09/84 81364 04/01/80 08/16/82 81020 05/09/84 81366 04/01/80 08/16/82 81022 05/09/84 81401 06/13/85 81034 05/09/84 81403 06/13/85 81038 05/09/84 81431 06/13/85 81042 05/09/84 81501 05/09/84 81046 05/09/84 81601 05/09/84 81052 05/09/84 81810 10/01/82 81054 05/09/84 82201 12/27/82 01058 05/09/84 82202 12/27/82 81062 05/09/84 82203 12/27/82 81064 05/09/84 82204 12/27/82 81056 05/09/84 82205 12/27/82 81070 05/09/84 82206 12/27/82 81072 05/09/84 82207 12/27/82 81074 05/09/84 82208 12/27/82 01/01/84 81078 05/09/84 82209 12/27/82 81080 05/09/84 82210 12/27/82 81054 05/09/84 82211 12/27/82 01/01/84 81088 05/09/84 82301 07/01/83 81121 02/24/79 05/09/84 82701 05/26/86 81123 02/24/79 05/09/84 82710 10/01/76 05/23/84 81125 02/24/79 05/09/84 82711 03/31/76 05/23/84 81127 02/24/79 05/09/84 82712 03/31/76 05/23/84 81129 02/24/79 05/09/84 83522 01/01/S4 81131 02/24/79 05/09/84 83523 01/01/84 81133 02/24/79 05/09/84 83524 01/01/84 81135 02/24/79 05/09/84 83525 01/01/85 81137 02/24/79 05/09/84 E1526 01/01/84 81139 02/24/79 05/09/84 8.l527 01/01/84 81141 02/24/79 05/09/84 83722 01/01/84 81143 02/24/79 05/09/84 83723 01/01/84 81145 02/24/79 05/09/84 83724 01/01/64 81147 02/24/79 05/09/84 83725 01/01/84 81149 02/24/79 05/09/84 83726 01/01/24 2-3 i
LIST OF EFFECTIVE PROCEDURES Initial Cancellation Initial Cancellation Module issue Date Date Module issue Date Date
]
83727 01/01/84 j
83728 01/01/84
{
83729 01/01/84 I
84522 01/01/84 84523 01/01/84 84524 01/01/84 84525 01/01/84 84722 01/01/84 84723 01/01/84 84724 01/01/84 84725 01/01/84 84850 02/21/84 85102 01/01/79 86700 10/01/60 86721 01/01/84 86740 01/01/82 90712 04/01/79 90713 10/01/80 90714 10/01/80 92700 10/01/80 92701 04/01/77 92702 01/01/82 92703 08/15/81 92704 01/31/75 10/31/85 92705 05/30/75 10/31/85 92706 10/01/80 06/07/85 92709 10/01/80 92710 10/01/80 92711 10/01/80 92712 10/01/80 92715 10/01/78 08/13/84 92716 10/01/77 08/13/84 92717 08/15/81 10/31/85 92720 03/14/86 i
93701 10/01/80 08/13/84 93702 10/01/76 94600 10/01/80 94700 10/01/80 10/31/85 94702 10/01/80 94703 08/15/81 2=4 l
____-_______A
DIABLO CANYON 1/2 Region 5 SALP Rating Period 1 - 01/01/83 - 06/30/84 SALP Rating Period 2 - 07/01/84 - 07/31/85 SALP Rating Period 3 - 08/01/85 - 07/31/86 SALP Rating Period 1
2 3
1 2
3 1
2 3
Operations 42700 0
20 110 71709 0
0 0
92709 0
0 9
71707 743 1060 1549 71710 116 309 533 93702 80 290 384 Totals foe Operations: 939 1679 2585 Radiological Controls 79701 0
0 8
83726 0
0 38 84724 0
0 24 83722 0
14 32 83728 0
0 26 84725 0
15 d90 83723 0
12 0
84525 0
15 0
84850 1
0 12 83724 0
0 16 84722 0
0 14 86721 0
0 18 83725 0
0 18 84723 0
0 17 Totals for Radiolecical Controls:
1 56 313 Maintenance 62700 0
0 149 62703 83 223 217 62705 0
0 23 62702 56 93 79 62704 0
0 37 Totals fo-Maintenance: 139 316 505 Surveillance 61700 0
94 54 61719 0
50 0
61725 24 72 75 61709 0
0 12 61720 0
0 16 61726 108 171 222 61711 0
0 10 61724 0
0 0
72700 0
0 4
Totals for Surveillance: 132 357 39' e
2-5
DIABLO CANYON 1/2 Region 5 SALP Rating Period 1 - 01/01/83 - 06/30/84 SALP Rating Period 2 - 07/01/84 - 07/31/85 SALP Rating Period 3 - 08/01/85 - 07/31/86 SALP Rating j
Period 1
2 3
1 2
3 1
2 3
i Fire Protection 64703 0
24 0
64704 20 57 60 i
Totals for Fire Protection:
20 81 60 Emergency Preparedness 82201 27 31 6
82205 12 0
4 82301 76 126 329 82202 8
3 0'.
6-82206 27 42 20 82712 0
0 0
82203-10-18 6
82209 0
0 7
82204 8
36 15 82210 8
33 IS Totals for Emeroency Preparedness: 170 316 408 Security 81018 0
1 1
81054 0
5 0
81078 0
2 1
81020 0
2 0
81058 0
2 0
81080 0
3 0
81022 0
4 1
81062 0
1 1-81084 0
2 0
81034 0
3 2
81064 0
2 0
81088 0
1 1
81038 0
5 1
81066 0
2 0
81501 4
2 0
81042 0
2 0
81070 0
4 10 81601 3
1 0
81046 0
4 0
81072 0
1 0
81810 10 0
0 81052 0
3 2
81074 0
1 0
85102 0
10 20 Totals for Security:
17 63 4:
1 Outages 35750 0
0 44 37702 0
32 53 73052 0
12 0
37700 0
73 59 72701 1
0 0
73755 0
0 41 37701 0
0 4
73051 0
12 0
Teta's fee Outa;es:
1 :I; 2:'
l 2-6
a DIABLO CANYON 1/2 Region 5 SALP Rating Period 1 - 01/01/83 - 06/30/84 SALP Rating Period 2 - 07/01/84 - 07/31/85 SALP Rating Period 3 - 08/01/85 - 07/31/86 SALP Rating Period 1
2 3
1 2
3 1
2 3
Quality Programs 35701 0
65 0
40700 22 0
0 92701 85 63 147 35751 0
0 2
40702 4
8-0 92702 57 20 33 36100-0 0
53 40704 12 0
0 92703 IS 54 79-36701 0
0 0
50095 0
0 86 92704 78 45 26 38700 0
0 0
65051 0
0 30 92705 862 '663 44 38702 0
0 25
-90712 0
0 36 92706 821 E56 0
39701 0
0 0
90714 0
0 0
92717 15 56 6
39702 0
0 0
92700 45 61 176 Totals for Quality Programs: 2016 1891 743 Licensing Activities 94702 0
0 0
Totals for Licensine Activities:
0 0
0 Training and Qualification 41400 0
0 42 41700 10 42 0
41701 10 34 35 I
Tetals fee Trainine and Qualification:
20 76 E0 I
2-7 i
e h_
)
3 i
PALO VERDE 1/2/3 Region 5 SALP Rating Period 1 - 07/01/81 - 02/28/83 SALP Rating Period 2 - 03/01/83 - 03/31/84 SALP Rating Period 3 - 04/01/84 - 09/30/85 j
i SALP Rat 1ng i
Period 1
2 3
1 2
3 1
2 3
Operations 42700 0
0 42 71710 0
0 39 93702 0
0 101 71707 0
0 1151 92711 0
0 4
2 Totals for Operations:
0 0 1337 Radiological Controls 84850 0
1 0
Totals for Radiological Controls:
0 1
0 Maintenance 62730 0
0 4
62702 0
0 13 62703 0
0 41 Totals fer Maintenance:
0 0
SE Surveillance 61700 0
0 65 61703 0
0 8
61708 0
0 16 61701 0
0 8
61705 0
0 5
61726 0
0 44 61702 0
0 8
61707 0
0 5
Totals for Surveillance:
0 0 159 2-B
r t
PALO VERDE 1/2/3 Region 5 SALP Rating Period 1 - 07/01/81 - 02/28/83 SALP Rating Period 2 - 03/01/83 - 03/31/84 SALP Rating Period 3 - 04/01/84 - 09/30/85 SALP Rating Period 1
2 3
1 2
3 1
2 3
Fire Protection 64703 0
34 4
64704 0
0 39 Totals for Fire Protection:
0 34 43 Emergency Pre aredness 82204 0
0 20 82210 0
0 20 82206 0
0 40 82301 0 128 162 Totals for Emercency Preparedness:
0 128 242 Security 81018 0
0 4
81054 0
0 2
81078 0
0 9
81020 0
0 3
81058 0
0 2
81080 0
0 2
81022 0
0 7
81062 0
0 2
81084 0
0 3
81034 0
0 8
81064 0
0 2
81088 0
0 2
81C38 0
0 7
81066 0
0 4
81501 0
0 3
81042 0
0 7
81070 0
0 7
81601 0
0 1
81046 0
0 2
81072 0
0 1
85102 0
28 0
81052 0
0 6
81074 0
0 1
Totals for Security:
0 2B E!
Outages 37700 0
0 6
Totals fer Outaces:
O C
6 l
l 2-9 l
__.._______________________m__
.M
1 PALO VERDE 1/2/3 Region 5 SALP Rating Pariod 1 - 07/01/81 - 02/28/83 SALP Rating Period 2 - 03/01/83 - 03/31/84 SALP Rating Period 3 - 04/01/84 - 09/30/85 SALP Rating heied 1
2 3
1 2
3 1
2 3
Quality Programs 38702 0
0 8
92701 0
0 157 92706 0
0 416 90712 0
0 4
92702 0
0 20 92716 0
0 2
90713 0
0 28 92704 0
0 18 92717 11 2 142 92700 0
0 155 92705 0
0 161 Totals for Quality precrams:
11 2 1111 Training and Qualification 41700 0
0 29 41701 0
0 36 Totels for Trainino and Qualification:
0 0
65 l
2-10 a
o.
o RANCHO SECO 1 Region 5 SALP Rating Period 1 - 10/01/82 -'11/30/83 SALP Rating Period 2 - 12/01/83 - 05/21/85 SALP Rating Period 3 - 06/01/85 - 06/30/86 SALP Rating Period 1
2 3
1 2
3 1
2 3
Operations 42700 0
0 101 71710 38 124 121 92712 0
0 2
71707 396 936 513 71715 0
0 438 93701 26 0
0 71709 157 0
0 86700 8
7 0
93702 48 579 1718 Totals. for Oce ations: 673 1646 2293 Radiological Controls 80721 0
16 0
83724 0
30 12 84722 0
12 0
83522 0
0 69 83725 0
12 30 84723 0
8 46 83523 0
0 20 83726 0
19 0
84724 0
16 30 83524 0
0 36 83727 0
1 4
84725 0
64 54 83526 0
0 38 83728 0
19 20 84850 0
0 4
83722 0
18 8
83729 0
24 II 86721 0-10 20 83723 0
18 8
84523 0
0 10 86740 12 0
0 Totals for Radielecital Centrols:
12 267 422 Maintenance 62700 0
64 4
62703 109 301 297 62705 0
0 4;
62702 0
0 50 62704 0
0 2
Totals fer Maintenance: 109 365 393 Surveillance 61702 0
0 0
61719 23 0
0 61726 85 145 255 l
61709 0
0 0
61725 15 0
59 72700 0
0 2'
Tetals for Surveillance: 123 l'!
33E 2~11 we.
e - m
- Q 0
RANCHO SECO 1 Region 5 SALP Rating Period 1 - 10/01/82 - 11/30/83 SALP Rating Period 2 - 12/01/83 - 05/21/85 SALP Rating Period 3 - 06/01/85 - 06/30/85 SALP Rating Period 1
2 3
1 2
3 1
2 3
Fire Protection 64703 0
36 10 64704 0
36 20 Totals for Fire Protection:
'O 72 30 Emergency Preparedness 82201 16 25 2
82205 8
0 0
82710 0
0 0
82202 16 IS 0
82206 15 33 18 82711 0
0 0
82203 8
21 2
82210 9
10 0
82712 0
0 0
82204 6
42 0
82301 80 194 159 Totals for Emeroency Preparedness: 158 340 191 Security 81018 0
0 23 81054 0
3 41 81078 0
1 11 81020 0
2 25 81058 0
1 2
81080 0
1 28 81022 0
0 38 81062 0
2 8
81084 0
1 5
81034 0
3 12 81064 0
1 5
81088 0
1 6
81038 0
2 65 81066 0
1 8
81501 0
4 24 81042 0
2 15 81070 0
2 65 81601 0
2 5
81046 0
1 9
81072 0
2 15 81810 6
1 0
81052 0
3 3
81074 0
1 9
85102 32 0
32 Tetals for Securitv:
35 37 4!!
Outages 37700 27 23 176 60710 9
50 0
73052 2
0 C
37701 0
22 20 71708 34 0
0 73753 16 0
C 37702 0
13 100 71711 0
0 10 73755 7
C C
60705 7
24 0
72701 0
0 22 Tetals fer Outaces: 102 13I 325 2-12
4 l
RANCHO SECO 1 Region 5 SALP Rating Period 1 - 10/01/82 - 11/30/83 SALP Rating Period 2 - 12/01/83 - 05/21/85 SALP Rating Period 3 - 06/01/85 - 06/30/86 SALP Rating Period 1
2 3
1 2
3 1
2 3
Quality Programs 35701 0
34 16 40701 0
0 40 92703 30 3
90 35751 0
0 48 40704 21 0
0 92704 44 119 129 36100 0
0 20 65051 0
10 0
92705 208 121 10 36700 0
0 6
90712 1
1 13 92706 465 1317 233 37703 0
0 8
90713 5
6 20 92716 3
0 0
38700 0
0 0
92700 170 518 210 92717 13 24 16 39701 0
0 0
92701 15 54 389 40700 0
34 0
92702 23 19 112 Totals for Ouality Procrams: 998 2260 1360 Licensing Activities 94702 0
4 26 Totals for Licensine Activities:
0 4
26 Training an: Qualification 41700 0
40 0
41701 38 40 8
Totals for Training and Ovalification:
38 80 8
4 2-13 i
SAN ONOFRE 1/2/3 Region 5 SALP Rating Period 1 - 07/01/81 - 06/30/82 5 ALP Rating Period 2 - 06/01/83 - 09/30/84 3 ALP Rating Period 3 - 10/01/84 - 05/31/86 SALP Rating Period 1
2 3
1 2
3 1
2 3
Operations 42700 12 0 145 71710 0 164 430 93701 8
0 0
71707 80 1147 3237 86700 1
0 5
93702 140 266 1661 71709 87 0
0 92712
'O O
10 Totals for Operations: 328 1577 5482 Radiological Controls 79701 0
0 22 03726 0
0 32 84723 0
6 41 80721 0
10 25 83727 0
0 25 84724 0
6 82 83527 0
0 6
83728 0
4 9
84725 0 104 209 83722 0
3 28 83729 0
4 73 84850 0
4 0
83723 0
4 30 84523 0
0 10
- 86721, 0
0 18 83724 0
6 58 84524 0
0 10 86740 30 20 0
83725 0
4 29 84722 0
0 40 Totals for Radiological Centrels:
30 175 747 Maintenance 62700 17 26 156 627C2 0
16 3C 62703 79 259 745 Totals for Maintenance:
96 301 93:
Surveillance 61700 3
0 115 61709 0
0 8
61724 9
8 C
61702 12 0
4 61710 2
0 13 61725 10 0 106 61705 0
0 5
61711 0
0 0
61726 87 129 672 l
61706 3
0 4
61719 20 0
92 61729 0
0 6
i 61707 3
0 6
61720 0
0 15 72700 4
0 7
61708 1
0 10 61721 30 0
0 j
l Teta,s <e. su venia-te: :s: 13 : e3 2-14
{
i W "
i
.l
O C
SAN ONOFRE 1/2/3 Region 5 SALP Rating Period 1 - 07/01/81 - 06/30/82 SALP Rating Period 2 - 06/01/83 - 09/30/84 SALP Rating Period 3 - 10/01/84 - 05/31/E6 SALP Rating Period 1
2 3
1 2
3 1
2 3
Fire Protection 64703 36 0
0 64704 0
16 83 Totals for Fire Protection:
36 16 83
, Emergency Preparedness 82201 0
24 46
.82205 0
0 6
82210 0
0 33 82202 0
17 6
82206 0
10 55 82211 0
18 0
82203 0
24 28 82208 0
21 0
82301 0 130 128 82204 0
10 55 82209 0
0 3
Totals.for Emercency Preparedness:
0 254 360 Security B1018 0
0 3
81054 0
0 9
81078 0
0 5
81020 0
0 3
81058 0
0 3
81080 0
0 5
81022 0
0 13 81062 0
0 5
81084 0
0 6
81034 0
0 11 81064 0
0 3
81088 0
0 2
81038 0
0 15 81066 0
0 2
81501 0
4 6
81042 0
0 5
81070 0
0 34 81601 0
2 2
l 81046 0
0 4
81072 0
0 3
81810 0
3 0
81052 0
0 5
81074 0
0 2
SS102 30 5
31 I
Totals for Security:
30 14 177 Outages 35750 0
0 66 57080 0
0 90 71711 0
C 13 37700 23 78 21 57090 0
0 120 72701 40 0
E!
37701 0
36 166 57700 0
0 36 73051 0
8 4f 37702 0
24 44 60705 9
0 62 73052 0
E 21 56700 10 0
17 60710 19 0 314 73753 19 0
El 57070 0
0 100 71708 325 0
0 73755 0
f Totals for Outaces: 415 I!' :.*'"
2-15
i SAN ONOFRE 1/2/3 Region 5 SALP Rating Period 1 - 07/01/81.06/30/82 SALP Rating Period 2 - 06/01/83 - 09/30/84 SALP Rating Period 3 - 10/01/84 - 05/31/86 SALP Rating Period 1
2 3
1 2
3 1
2 3
Quality Programs
-35701 4
77 52 40700 3
0 48 92702 39 84 77 35751 0
0 '11 40701 0
15 13 92703 42 33 227 36100 0
0 6
40702 0
0 71 92704 0
0 42 36700 4
0 9
40704 9
0 0
92705 15 1
83 37703 5
0 0
65051 0
0 17 92706 244 2105 1428 38701 33 50 54' 90712 5
64 112 92716 1
1 0
3B702 14 23 8
90714 5
0 0
92717 12 8
66 39701 0
0 20 92700 144 256 468 39702 0
61 0
92701 181 34 553 Totals for Quality Procrams: 740 2812 3365 Licensing Activities 94702 0
0 17 Totals for Licensin; Activities:
0 0
17 Training and Qualification 41400 0
0 18 41700 13 15 144 41701 36 0
24 Totals for Training and Qualification:
de 15 les 2-16 M
M
..m.
__d
1 i
TROJAN Region 5 SALP Rating Period 1 - 09/01/82 - 08/31/83 SALP Rating Period 2 - 09/01/83 - 10/31/84 SALP Rating Period 3 - 11/01/84 - 10/31/85 5 ALP Rating Period 1
2 3
1 2
3 1
2 3
Operations 42700 0
33 45 71709 107 0
0 71714 0
4 4
71707 261 732 759 71710 3 100 110 93702 0 302 178 Totals for Operations: 371 1171 1096 Radiological Controls 79701 0
0 4
83726 0
6 0
84724 0
0 25 80721 0
6 0
83727 0
0 3
84725 0
41 55 83722 0
5 10 83728 0
0 0
84850 0
10 0
83723 0
5 10 83729 0
2 25 86721 0
22 11 83724 0
11 0
84722 0
0 8
86740 22 0
0 4
83725 0
5 16 84723 0
0 27 l
Totals for Radiolecital Centro 1:.:
22 113 19:
Maintenance 62700 13 0
10 62702 0
20 30 62704 0
0 17 62701 31 0
0 62703 74 257 108 62705 0
0 17 Totals for Maintenance: 118 277 182 Surveillance 61700 13 16 98 61708 0
0 4
61725 12 0
10 61701 8
12 10 61709 0
0 5
61726 89 207 91 61702 0
0 7
61710 0
0 7
61729 6
0 0
61705 0
0 3
61711 0
0 3
72700 36 22 4
61706 0
0 4
61720 12 15 21 61707 0
2 0
61724 0
0 10 Totals for Surveillance: 176 274 27' 2-17 4
TROJAN Region 5 SALP Rating Period 1 - 09/01/82 - 08/31/83 5 ALP Rating Period 2 - 09/01/83 - 10/31/84 5 ALP Rating Period 3 - 11/01/84 - 10/31/85 3ALPRat1ng Perted 1
2 3
1 2
3 1
2 3
Fire Protection 64703 0
0 24 64704 12 0
18 Totals for Fire protection:
12 0
$2201 10 14 0
82204 15 14
- 18 82210 13 14 18.
82202 15 14 '-
0 82205 10 0
0 82301 0 234 177 82203 15 14 0
82206 10 14 30 82712 79 0
0 Tetals for Emeroency Preparedness: 167 318 243 Security 81018 0
0 4
81054 0
0 3
81078 0
0 2
81020 0
0 1
81056 0
0 3
81080 0
0 3
81022 0
0 1
81062 0
0 3
81084 0
0 3
81034 0
0 3
81064 0
0 3
81088 0
0 1
81038 0
0 3
81066 0
0 1
81501 0
2 6
81042 0
0 3
81070 0
0 5
81601 0
0 4
81046 0
0 3
81072 0
0 4
81810 6
0 0
81052 0
0 1
81074 0
0 2
Totals fe-Security:
6 2
62 Outages 35750 0
0 27
- 0705 17 10 11 73052 8
0 51 37700 0
21 25 40710 45 76 56 73753 8
0 C
37701 0
0 30 71711 14 0
34 73755 8
0 15 37702 0
27 20 72701 0
0 3
56700 10 30 43 73051 0
0 12 Tetals fee Outaees: 110 36' 33:
2-18
)
TROJAN Region 5 l
SALP Rating Period 1 - 09/01/82 - 08/31/83 SALP Rating Period 2 - 09/01/83 - 10/31/84 SALP Rating Period 3 - 11/01/84 - 10/31/85 SALP Rating Period 1
2 3
1 2
3 1
2 3
Quality Programe 35701 3
8 12 39702 0
23 24 92701 42 43 68 35751 6
6 0
40700 1
25 28 92702 2
0 3
36100 0
0 6
40701 0
16 20 92703 11 8
10 36700 4
20 10 40702 0
10 53 92704 1
0 43 37703 0
10 0
40703 6
6 15 92705 5
83 32 38700 6
44 0
40704 1
10 10 92706 169 842 220 38701 0
39 1
50095 0
0 46 92717 6
1 46 38702 0
64 0
90714 0
9 26 39701 0
25 0
92700 58 68 59 Totals for Quality Procrams: 321 1360 73'?
Training and Qualification 41700 16 29 38 41701 12 96 12 l
Tetals for Training and Qualification:
28 125 50 l
l 2-19
WASHINGTON NUCLEAR 2 Region 5 SALP Rating Feriod 1 - 08/01/82 - 07/31/83 SALP Rating Period 2 - 08/01/83 - 01/31/85 SALP Rating Period 3 - 02/01/S5 - 01/31/86 SALP Rating period 1
2 3
1 2
3 1
2 3
Operations 42700 0
0 46 71710 0 140 48 93702 0
15 219 72707 0- 775 841 71714 0
8 6
Totals for Operations:
0 938 1160 Rad,iological Controls 79501 0
0 2
83726 0
2 4
84724 0
0 3B B3722 0
0 4
83727 0
2 5
84725 0
46 24 83723.
0 0
4 83728 0
5 4
84850 0
1 18 83724 0
4 5
84722 0
0 18 86721 0
0 20 83725 0
0 4
84723 0
0 38 Totals for Radiolecic'al Controls:
0 60 188 Maintenance 62700 0
0 20 62702 0
48 29 62703 0 130 90 Totals for Maintenance:
0 178 139 Surveillance 61700 0
0 60 61725 0
13 49 61702 0
0 1
61726 0 179 125 Tetals for Surveillance:
0 192 73E 4
2-20 l
i I
_____-_-__-_____________m
- =,
i' l
WASHINGTON NUCLEAR 2 Region 5 SALP Rating Period 1 - 08/01/82 - 07/31/83 SALP Rating Period 2 - 08/01/83 - 01/31/85 SALP Rating Period 3 - 02/01/85 - 01/31/86 SALP Rating Period 1
2 3
1 2
3 1
2 3
fire Protection 64704 0
12 45 Totals for Fire protection:
0 12 45 Emergency Preparedness 82204 0
0 20 82210 0
0 20 82206 0
20 30 82301 78 173 154 Totals for Emercency Preparedness:
78 193 224 Security 81018 0
0 2
81054 0
0 3
81078 0
0 4
81020 0
0 1
S1058 0
0 2
81080 0
0 7
81022 0
0 1
81062 0
0 2
81084 0
0 2
81034 0
0 2
81064 0
0 5
81088 0
0 1
81038 0
0 5
81066 0
0 2
81501 0
13 4
81042 0
0 5
81070 0
0 1
81601 0
9 2
81046 0
0 0
81072 0
0 1
81810 0
7 C
81052 0
0 2
81074 0
0 1
85102 0
4 0
Totals for Security:
0 33 55 Outages 35750 0
0 83 56700 0
12 0
73052 0
0 l0 37700 0
0 38 72701 0
0 2
37702 0
0 70 73051 0
0 14 Tetals fe-Outaees:
0 I? 2:"
2-21
WASHINGTON NUCLEAR 2 Region 5 SALP Rating Period 1 - 08/01/82 - 07/31/83 5 ALP Rating Period ? - 08/01/83 - 01/31/85 SALP Rating Period 3 - 02/01/85 - 01/31/86 SALP Rating Period 1
2 3
1 2
3 1
2 3
JQuality Programs 35701 0
0 64 40704 0
0 6
92704 0
0 20 39701 0
0 7
50095 0
0 16 92705 0
15 60 39702 0
0 6
90712 0
17 41 92706 9 323 123 40700 0
13 50 92700 0 139 55 92716 0
8 0
40701 0
0 1
92701 5 176 452 92717 39 9
24 40702 0
0 25 92702 0
32 50 40703 0
0 7
92703 5
18 29 Totals for Quality Programs:
58 750 1036 Training and Qualification 41700 0
32 59 41701 0
6 1
Totals for Traieine and Qualification:
0 3e 60_
2-22
[
1 J';, _
. t o
s
~
b i
1 ENCLOSURE 3
.f.
$1 INSPECTION RESOURCE ALLOCATION y
FOR PLANTS OF INTEREST p
REGION.5
./
NOTE:! The ' Plants of Interest' are the two plants in each Region with the
\\ highest and lowest combined SALP ratings for Operations, Maintenance,
' ' ' - and Surveillance. Where identical SALP ratings exist for several plants in those areas, tt.o selection of Highest / Lowest plant'is based on an average of the ratings assigned in the remaining functional areas.
The inspection hours and SALP ratings are for the latest SALP report period.
/
)
OPERATIONS MAINTENANCE SURVEILLANCE Insp. Hours /
Insp. Hours /
Insp. Hours /
\\
SALP Rating SALP Rating SALP Rating
" Plants with the s HIGHEST Ratings DIABLO CANYON 1/2 2565 / 2 505 / 1 393 / 2 I'
TROJAN 1096 / 2 182 / 2 277 / 2 i
Plants with tne LOWEST Ratings t
WNSHINGJONNUCLEAR2 1160 / 2 139 / 2 238 / 2 i<'
.}
i, R$WCHOSECdj 2893 / 3 393 / 3 33S / 2 1
- t -
s Averige Inspection' 1323.5 201.0 224.4 Hours for the Region (All Plants) q j
?
-l J
3-1 m
f --
.. Dennis F. Kirsch Distribution (w/ enclosure)
DC5 DI Reading ORPB Reading JGPartlow-
/
RL5pessard PFMcKee til. Wheeler MJohnson i
0 4
R e
l December 31, 1986 APPENDIX 8 MEMORANDUM FOR: James M. Allan, Deputy Regional Administrator Region I ROM:
James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ELAPSED TIME TO ISSUE REACTOR INSPECTION REPORTS t
'It is important th'at reports of NRC inspections be issued with reasonable promptness in order to comunicate fonnally to the licensee any results that require corrective action on the part of the licensee. The report also infoms interested NRC management and staff and outside parties about the current status of plant problems and licensee perfonnance. In this connection, IE Manual
{
Chapter 0610-07 sets a goal of 20 calendar days for issuance of inspection l
reports with a 10 day extension to 30 calendar days for reports of major team inspections, To determine how well the regions are meeting the elapsed time goal specified in the IE Manual, we obtained data from the 766 system regarding reactor inspection reports issued during FY 1986. These data indicate an average time of 37 days for reports issued by Region I during that period. Enclosed is a copy of,the computer printout which provides the details of how the average time was computed. After reviewing these data I am sure you will agree that increased attention should be devoted to the matter of shortening the time between the end of the inspection and the issuance of the report.
We appreciate your cooperation in striving to reduce the elapset time for inspect, ion reports. If you have any questions or coments about this matter, please call me.
I would be happy to discuss them with you.
0?l*B:'. i _' ']0d nds G. r,nr...
James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Computer Printout
_______.__________________________m____
s 9
December 31, 1986 MEMORANDUM FOR: Malcolm L. Ernst Deputy Regional Administrator Region II FROM:
James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ELAPSED TIME TO ISSUE REACTOR INSPECTION REPORTS It is important that reports of NRC inspections be issued with reasonable
. promptness in order to comunicate fomally to the licensee any results that require corrective action on the part of the licensee. The report also informs interested NRC management and staff and outside parties about the current status of plant problems and licensee performance. In this connection, IE Manual Chapter 0610-07 sets a goal of 20 calendar days for issuance of inspection reports with a 10 day extension to 30 calendar days for reports for major team inspections.
To determine how well the regions are meeting the elapsed time goal specified in the IE Manual, we obtained data from the 766 system regarding reactor inspection reports issued during FY 1986. These data indicate an average time of 35 days for reports issued by Region II during that period. Enclosed is a copy of the computer printout which provides the details of how the averege time was computed. After reviewing these data I am sure you will agree that increased attention should be devoted to the matter of shortening the time between the end of the inspection and the issuance of the report.
We appreciate your cooperation in striving to reduce the elapsed time for inspection reports. If you have any questions or cor:nents about this matter, please call me.
I would be happy to discuss them with you.
CT.!NAL S!GMD BY:
1AMLS G. FARTLow James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Computer Printout
)
= _ _ - _ _ - _ - _ _ _ _ _
a
- a December 31, 1986 MEMORANDUM FOR:
A. Bert Davis, Deputy Regional Administrator Region III FROM:
James G. Partlow Director Division of Inspection Programs Office of Inspection and Enforcement ELAPSED TIME TO ISSUE REACTOR INSPECTION REPORTS
SUBJECT:
I want to conenend'Regiori III on the fine record you have achieved for FY 1986 in essentially meeting the goal for prompt issuance of inspection reports.
The IE Manual sets a goal of 20 calendar days for issuance of inspection reports with a 10 day extension to 30 calendar days for reports of major Data obtained from the 766 system for FY 1986 gave an team inspections.
average elapsed time of 22 days from the end of the inspection until the report was issued by Region Ill. Enclosed is a copy of the computer printout th6t gives the data for your region.
~
I am sure the excellent results achieved in this area can be attributed to the active interest and attention of Region III management and staff, ca p.:1 rGNED BY:
AM:is G. ?XJM James G. Partlow, Director Division of Inspection Programs Office of Inspection and E1forcement
Enclosure:
Computer Printout
J as December 31, 1986 MEMORANDUM FOR: Paul S. Check, Deputy Regional Administrator Region IV FROM:
James G. Partlow, Director D. vision of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ELAPSED TIME TO ISSUE REACTOR INSPECTION REPORTS It is important that reports of NRC inspections be issued with reasoriable promptness in order to communicate formally to the licensee any results that require corrective action. These reports also inform interested NRC management and staff and outside parties about the current status of plant problems and licensee perfonnance. In this connection IE Manual Chapter 0610-07 sets a goal of 20 calendar days for issuance of inspection reports with a 10 day extension to 30 calendar days for reports of major team inspections.
To determine how well the regions are meeting the elapsed time goal specified in the IE Manual, we obtained data from the 766 system regarding reports of
)
reactor inspections that were made during FY 1986. These data indicate an average elapsed time of 62 days for Region IV reactor inspection reports.
Enclosed is a copy of the computer printout which provides the details as te how the average elapsed time was computed. I am sure you will agres that significant attention needs to be focused on this aspect of the Region's operation so as to substantially reduce the time between the end of an inspection and the date when the report is issued.
I appreciate your cooperation in striving to reduce the time for issuance of inspection reports. If you have any questions or comments about this matter, I would be happy to discuss them with you.
CM"U.0~.C BY JAdS G. F4n06 James G. Partlow, Director Division 'of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Computer Printout
e December 31, 1986 1
MEMORANDUM FOR: Bobby.H. Faulkenberry, Deputy Regional Administrator
' Region V FROM:
Janes G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ELAPSED TIME TO ISSUE REACTOR INSPECTION REPORTS I want to commend Region V on the fine record you have achieved for FY 1986 in meeting the goal for prompt issuance of inspection reports. The IE Manual l
sets a goal of 20 calendar days for issuance of inspection reports with a 10 day extension to 30 calendar days for reports of major team inspections.
Data obteined from the 766 system for FY 1986 gave an average elapsed time of 20 days from the end of the inspection until the report was issued by Region V.
Enclosed is a copy of the computer printout that gives the data for your region.
I am sure the excellent results achieved in this area can be attributed to the active interest and attention of Region V management and staff.
c.
- t r "n: SY:
js. is G. Eni.iiCd James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Computer Printout i
APPENDIX 9 DEC 191986 NOTE TO:
Anthony T. Gody, DRMA, Pegion 1 Richard J. Maley, DRMA, Region 11 Gen W. Roy, ORMA, Region III William H. Foster, DRMA, Region IV Kathleen Hamill, OPMA, Region V FROM:
James L. Blaha, IE
SUBJECT:
TIMELINESS STAT!STICS FROM 766 SYSTEM Recently we gathered statistics on the time taken to issue an inspection report Calendar days of and the time taken to initiate a 765 record of an inspection.
elapsed time were calculated for each 766 record of an inspection completed in FY 1986 (i.e., report issued in FY 1986). Average number of days were calculated by docket and region. I enclose the appropriate sections for your region.
Elliott Greher (FTS 497-4969) is available to assist you in reviewing this data.
The overall results are:
(Field) Inspect To Date Issue Report Date Until Until Issue Pecort Date 766 Record Create Date Non-050 Non-050 050 Deckets Dockets 050 Dockets Dockets c gion !
37 Days 39 Days 75 Days 114 Days e
Region !!
36 13 22 27 Pegien III 2.
6 27 27 Region IV 6.7 23 24 39 Region V 20 10 35 56 All Pegions 33 21 37 60 DI has responsibility 'or the results for inspection report time',iness.PSAS is concerned with the cuality assurance and timeliness of 766 records. I excect to include these statistics in a cuality assurance focus on 766 data which we are undertaking in accordance with IE MC 0537. I would aporeciate your corrects on the time lag for data entry into the 766. Other corrents with resoect to your region's process for 766 data entry, the responsible person fer 766 cu!'i y and timeliness and recorredaticn for a reascnable tire gcal would be help #ul.
o.
.'C.C i%
/ James L. Blaha, !E Encicsures:
As Stated
A e Esh.
UNITED STATES
,4*.
g%,
NUCLEAR REGULATORY COMMIS$ TON APPENDIX 10 i
e t
nacioN I E
j sai pann Avenus mano op enussia.esumsvLvania suos JAN 2 51937 MEMORAN0UM FOR: James L. Blaha, Director Program Support and Analysis Staff Office of Inspection and Enforcement FROM:
Anthony T. Gody, Director Division of Resource Management and Administration Region I
SUBJECT:
TIMELINESS STATISTICS FROM 766 SYSTEM As requested in your memorandum dated December 19, 1986, we have reviewed the timeliness statistics for our region and discussed these statistics with regional personnel involved in the 766 System.
We have also reviewed IE MC 0535 and 0537 and recognize that both manual chapters and the NRC Forms 766 and 766-A require updating in order to enable meaningful implementation of quality assurance audits.
To improve our timeliness in the area of data entry, we have developed a 766 tracking system and DRMA procedures and regional instructions that document the processing and handling of NRC Forms 766 and 766-A in Region I.
We are also issuing a 766 Newsletter that will be sent periodically to Region I technical personnel for the purpose of prov.iding further supplemental guidance to improve the accuracy of the 766 data. Supplem!ntal guidance is also being discussed with Elliott Greher, IE, and my staff before issuance of the 766 Newsletter.
Region III's recommendation of 21 days appears to allow sufficient time for the prccessing, handling and quality assurance of the 766 Forms.
John Mc0 scar, Chief, Resource Management Branch, is the person responsible for 766 quality and timeliness, and should be informed of any areas focusing on the 766 system. Nancy Young has been designated as the 766 Coordinator.
I can assure you that once our procedures become effective, our timeliness statistics will reflect a more f avorable trend.
If you have any questiens regarding this matter, I can be contacted at FTS 488-1350.
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/* pe ** cqo, UNITED STATES APPENDIX 11 l'
NUCLEAR REGULATORY COMMISSION 3-
.,1 wass NcTON. D. C. 20555 a
gv.....f DEC 17 0
?!EMOPANDUM FOR:
Victor Stello, Jr.
Executive Director for Operations FROM:
Robert D. Martin Regional Administrator
SUBJECT:
01ARJPORTREVIEW: OIA FILE NO. 86-10 This memorandum contains my proposals for dealing with the implications of the OIA Report's findings.
In this regard, I reserve the right to propose and take additional or alternative actions as I explore the matter more thoroughly with the staff.
The OIA report is broken into three main sections. Each section pertains to one of the allegations as generally formulated by OIA. The allegations and ny recommendations are as follows:
Allecatior I:
" Region IV management harassed and intimidated inspectors to pressure them to downgrade or delete proposed inspection findings at CPSES."
This allegation was not substantiated by OIA.
There was no evidence of such action by Region IV management.
Indeed, upon examination of the recore, it is clear that, insofar as particulars go, the allecation was directed solely at one supervisor by one inspector.
The review by OIA of the several ipecific technical issues which were in contention between certain inspectors and this supervisor does not provide a definitive determination as to first, their safety significance, and second, the appropriateness of their handling.
To provide me an independent view "n these matters, I request that you convene a suitable, high level review group, supported by appropriate technical staff, to dc a concrehensive review of each issue in contention.
To support that effort, I will temporarily detail Messrs. Westerman and Phillips from their present duties to be at the oisposal of that review group on a full-time basis until the review of the issues is complete. Other Region IV personnel, as identified by the review group, will be made available as requested.
Upon completion of that review-group effort, I will be t.ble to fir.alize my recommendations as to any further actions.
However, there are a number of issues in the report which are sufficiently developed to make clear the appropriate corrective actions.
I have initiated the following actiors:
In this regard, N
E NCL OS:E '.
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a Fe-training of all technical staff and supervision will be conducted on Regional Policy Guide 2201, which was issued in August 1986, 6nd which affirms the positive obligation on both the staff and supervision / manage-ment to escalate disagreements promptly to achieve resolution. This should, if followed, preclude protracted discussions on such issues in the future.
I have instructed the Director of my Division of Resource Man 6gement and Administration to develor en improved inspection report tracking system that will identify those reports that are experiencing unacceptable delays in the various stages of their preparation, review, approval, and distribution. This is to be operational by February 15, 1987, and will alert senior regional management to possible instances of protracted review.
g Training for all Region IV supervisors will be conducted to remind them l
of their proper supervisory responsibilities, including the need to give adequate direction and guidance, and identify and document weaknesses they discern in their subordinates. Supervisors will also be held l
accountable for developing, in such cases, suitable Individual Development l
Plans to address the problems. The assistance of the Office of l
Administration will be requested in conducting training in this area.
l Where training and guidance is indicated. I intend to pursue same with appropriate vigor. The OIA report and its attachments are being reviewed again to identify those several inspection practices for which further detailec guidance and retraining of technical staff is irdicated. These consist of practices about which the transcripts and other attachments clearly show non-uniform understanding by members of Pegion IV staff and supervision.
Allegation II:
"The Region IV OA' inspection program at CPSES was inadequate."
I believe that this conclusion can be accepted as written.
It reflects adequately one of the very purposes of the ef fort now underway at Corranche Peak which is to establish an adeouate confidence level at,out the design and construction of the Comanche Peak Units.
Based on the available information, OIA finds that it appears that at CPSES Region IV did not satisfy the f requency requirements for the IE Manual Chapter 2512 OA inspection procedures. OIA noted that the requirement changes over the years made it difficult to make such a determination. Consequently, 01A states that it " appears" that it would not be possible to rely on the Regicn IV QA inspection effort as evidence of the safe construction of CPSES.
This will necessitate reliance largely on the detailec technicel inspections of various structures, systers, and ccaponents that have recently been conducted by the NRC at CPSES.
Over the past several years, NRC has become increasingly concerned about TUGC0's OA prcgran at CDSES and, as a result, a nurter cf steos were begur to address those concerns culminating in the present review effort. WhPn this present revier effort is concleted, there shoulc be reasonable assurance tret CPES has been constructed in corpliance with safety regulations irrespective of earlier 0A problems.
4',
,a Allecation III:
" Data documented in Region IV's NRC Forn 766 Inspector's Report was inaccurate."
O' A found that, based on the information it developed, the data recorded on the NRC Form 766 pertaining to CPSES were inaccurate and unreliable.
In order to establish the significance of this finding, an analysis of the history, purpose, maintenance, and limitations of the 766 system would be needed.
I do not believe the significance of this subject warrants further efforts because substantive agency safety decisions are not based on the information contained in the 766 system.
Summa ry I am satisfied that the report basically reflects a series of prolonged disagreements between a supervisor and his subordinate. While future reviews may suggest the supervisor may not have always been right, no intimidation or harassment has been substantiated.
No improper intent or wrongdoing has been shown. While there were some derogatory comments made by several people other than the involved inspector, such comments are, in my view, unwarranted.
The overwhelming majority of Region IV personnel interviewed had no such problems in their dealings with management.
I an prepared to discuss my conclusions with you at your earliest convenience.
In the meantime, I will go forward with my current recommended actions: When the review group completes its efforts I will be prepared to carry out any appropriate actions that are identified by that review.
/s/
4 Robert D. Martin Pegional Administrator 1
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