ML20244D305

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Agrees w/850311 Suggestion That IE Develop Procedure to Implement 841203 Policy on Control of NRC Repts & Other Documents.Certain Existing Sections of IE Manual Should Be Changed.Preliminary Conclusions Noted
ML20244D305
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 04/10/1985
From: Taylor J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
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ML20237K807 List: ... further results
References
NUDOCS 8504240277
Download: ML20244D305 (3)
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c. NUCLEAR REGULATORY COMMISSION t :j WASHINCTON, D. C. 20555 l l

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MEMORANDUM FOR: James G. Keppler, Regional Administrator Region III  !

l FROM: James M. Taylor, Director Office of Inspection and Enforcement 1

SUBJECT:

FURTHER PROCEDURAL GUIDAtE ON THE POLICY ON CONTROL l OF NRC REPORTS AND OTHER DOCUMENTS j I

We agree with the suggestion in your March 11, 1985 memorandum that IE should i develop a procedure to implement the policy contained in the December 3,1984 i memorandum, " Policy on Control of NRC Reports and Other Documents," from W. J. Dircks, EDO. We plan to do this. In developing such a procedure, we must also consider the requirements contained in the October 7,1983 memorandum from Mr. Dircks, " Policy on the Distribution of Draft Inspection and Investiga-tion Reports."

Further, we agree that certain existing sections of the IE Manual should be changed to emphasize the policies contained in the memoranda cited above. We have reviewed those parts of the IE Manual listed in your March 11, 1985 memo- l randum and have developed the following preliminary conclusions:

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1. 3000 Series Inspection Procedures These procedures should be changed to emphasize the restrictient  ;

on dissemination of written materials and provide guidance, or 1 reference another part of the IE Manual for guidance, on the types of written materials that may be provided to licensees and the cir-cumstances under which such materials may be provided.

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2. MC 0610 - Inspection Reports Section 0610-09.02 discusses the policy relating to draft inspection reports. We believe this information is adequate. ,

Section 0610-09.03 contains guidance on providing inspection j findings orally or in writing. This guidance should be revised I to more explicitly explain the kind of written correspondence l that is permissible. Further, it is inappropriate to include

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such guidance in an instruction on the preparation of inspection j reports. We plan to olace this guidance elsewhere in the IE Manual, perhaps in the instruction to be developed to implement the two EDO policy statements. Finally, MC 0610 should contain ,

additional guidance regarding the need to include in an inspection j report copies of all written materials provided to a licensee.

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James.G. Keppler  !

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.j Such guidance should not be included in 0610-09, Release of Inspec-tion Reports, as is presently the case, but rather in 0610-05, Docu-mentation Requirements.

3. MC 0611 - Review and Distribution of Inspection Reports We believe that no changes are needed in this instruction.
4. MC 0235 - Conduct of Employees MC 0237 - Supplemental Statement on Conduct of Employees for Resident Inspectors These instructions deal with activities described in 10 CFR Part 0 and are not directly related to the dissemination of

~ written materials. Therefore, we believe these manual chapters 1 should not be changed to incorporate guidance on the type discussed herein. -

, 5. IP 94600 - Information Meeting With Local Officials IP 94703 - Media Centacts

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These procedures should be changed to describe the types of documents that mdy be released and those that should not be released.

I i 6. IE Inspection Training and Qualification Journal This' document should be changed so that the policy on control of NRC reports and other documents is specifically addressed.

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There do not appear to be any questions regarding the current policy relating to draft inspection and investigation reports. Additional guidance does seems to be necessary in the following additional areas:

The kinds of information and circumstances under which inspectors may provide written information "...to responsible licensee manage-ment to obtain prompt licensee evaluation and, if appropriate, safety related corrective actions." (Memorandum from ED0 i dated October 7, 1983)

The types of situations that meet the criteria, "In the event there is an emergency, or a significant' safety or safeguards issue appears to require immediate action, NRC personnel, at their discretion, may discuss with, show to, or provide the licensee with any pertinent material they believe the circum-stances warrant." (Memorandum from EDO dated December 3, 1984)

For exit interviews and enforcement meetings, provision of '

...a listing of significant issues developed in the course of 9 ,

-j James G. Keppler , an. inspection in order _to facilitate communication of inspection findings which require corrective action." (Memorandum'from ED0 l l

dated October 7,1983)

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  • i Written review. comments on licensee documents such as test and operating procedures.

With respect to the last item, it is instructive.to note that draft versions * '

o of the October 7,1983 policy statement contained examples of " permitted information exchanges" similar to this item. The final statement of policy issued,on October 7,1983, however, omits any such examples and may not permit this type of written communications.

We plan to work with the. staffs of Regional Offices, IE, and DEDROGR in the development of guidance and the promulgation of new or revised instructions.

The Division of Inspection Programs has the lead responsibility for this project. Regional Offices will be given.an opportunity to comment on all of 1

these instructions prior to issuance.

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  • James M. Taylor, Direct r Office of Inspection and Enforcement' cc: T. E._Murley RI J. N. Grace, RII R.-D..Nartin, RIV J. B. Martin, RV V. Stello, DEDROGR W. J. Dircks, EDO i

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