ML20245C647
| ML20245C647 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/28/1987 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20245C430 | List: |
| References | |
| FOIA-87-596 NUDOCS 8711030274 | |
| Download: ML20245C647 (9) | |
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MAY 2 81907 i
l MEMORANDUM FOR:
J. M. Taylor, Deputy Executive Director for Regional Operations FROM:
Robert D. Martin, Regional Administrator
SUBJECT:
REGION IV POLICY GUIDES (TRAINING ISSUES)
I recently provided the ED0 a memorandum regarding the status of training commitments I made on issues that evolved from the Comanche Peak OIA report.
I indicated that I would periodically provide copies of those training policy j
guides to you for review to assure that the general guidance being given was consistent with the Program Office approach. Enclosed are the following policy guides.
l RIV Policy Guides (Training Issues) 4004, Facts vs Opinions / Assertions and Conclusions in Inspection Reports 4007, Inspection of Applicant / Licensee Records - Power Reactors 4008, Quality Assurance Records Versus In-Process Documents 4009, Inspection of the Applicant's Construction Deficiency Reporting System 4010, Missed Windows of Opportunity for Inspection - Power Reactors 4011, Enforcement of Applicant / Licensee Policies 4013, Shipment of QA Records - Power Reactors 4015, 10 CFR 50.55(e) Rule 4016, Accuracy and Perspective During Interviews 4017, Role of the Hearing Process 4021, Citing of " Nits" i
Additional training policy guides are in various stages of development. As we complete the next group of them, I will forward them to you as well.
I intend to continue this general process to address basic work ethic and strategy issues to assure a consistent understanding by my staff members.
If you specifically desire separate copies, I will continue to send them to you.
T. O. Martin of your staff is currently on the distribution list for all regional policy guides and therefore has been receiving them as they are distributed. Unless I hear to the contrary, I will assume that is a satisfactory continuing arrangement.
ORIGINAt SIGNED BY ROBERT D. MARTIN Robert D. Martin Regional Administrator
Enclosures:
RIV Polic Guides RIV:RA[jc RDMgrtt :
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@L 1 o y Regional Office Policy Guide No. 4003, Revision 0 TRAINING ISSUE: CODE INTERPRETATION RESPONSIBILITIES A.
Purpose:
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To inform the staff of the uniform practice to be followed in the handling of the above type issue.
B.
Discussion:
The Regional staff is cautioned that the interpretation of a code or standard is not always straightforward. There are, for example, in the ASME Boiler and Pressure Vessel Code,Section III, certain articles of the code that are applicable during manufacturing and a different set of articles that are applicable during installation (cor.struction). A code article applying to manufacturing may not apply to installation.
When, during the course of an inspection, a question arises with regard to an interpretation of a code or standard, clarification should be requested from the Region IV Reactor Safety Branch.
If it is an imediate safety concern which could affect continued plant operation or endanger the health and safety of the public, then immediate clarification should be I
requested via the appropriate section chief to the Reactor Safety Branch.
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Otherwise, the inspectors should indicate to the licensee that further clarifit.ation within the NRC staff is being pursued.
Normally, there are members of the Region IV Reactor Safety Branch who can provide a ready verbal response to an interpretation question which is adequate for most situations.
If necessary, the Reactor Safety Branch will make the nonnal contacts with the appropriate NRC Headquarters staff for code and standard interpretations. One very brief telephone call can solve most code and standard interpretation issues. On a more controversial interpretation, a written request should be provided to the Reactor Safety Branch. Guidance from NRC headquarters will be requested by the Reactor Safety Branch as appropriate.
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C.
Action:
- All affected personnel are to adhere to the above practice starting on the effective date of this policy guide.
D.
Contact:
Any questions regarding this policy guide should be directed to T.
F.-
Westerman, Chief Reactor Safety Branch (ext. 145).
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Effective Date:
This guidance is effective on its date o ssuance.
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obert. Martin Regional Administrator
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=-mr Regional Office Policy Guide No. 4006, Revision 0 TRAINING ISSUE: UNRESOLVED ITEMS A.
Purpose:
To' provide the staff with an understanding of NRC policy concerning unresolved items; i.e., definition, identification, classification, prompt followup inspection requirements, and closure.
u B.
Discussion:
NRCManualChapter(MC)0610,'datedJanuary 27, 1984, defines an unresolved item as'a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. To fully understand the definition, emphasis must be placed on the words "... matter about which more information is required." This is the critical point that the inspector and his supervision must evaluate. Whenever there is enough information to
- 'S determine that licensee activities do not comply with requirements, a
' D, s violation or deviation should be cited. Such matters shall not be
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classified as unresolved.
The inspector is to identify unresolved items during the inspection, at the exit management meeting, and in the inspection report.
In those cases the inspector should clearly describe what information is needed, and'who-
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will provide it, to determine whether the licensee activity is acceptable or does not comply.'
.The use of unresolved items to avoid writing violations, or their use to force the licensee to exceed minimum requirements or perform safety-related activities in accordance with inspector.'s personal For exam le, it is not appropriate to preference is unacceptable. consider a violation unresolved until.p* corrective actions Completion of corrective actions i's.not information needed to classify an activity as not meeting regu atory requirements.
In those cases where the unresolved item will cause the licensee to perform work activities that, constitute backfit, the inspector shall consult and follow the NRC policy described in MC 0514 and Regional Policy
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Guide _(RPG)No.0701. Such instances are viewed as being very rare as the i
resolution of unresolved items is usually one of information rather than
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actual work activities. The inspector should bear this in mind before presenting the finding to the licensee in the exit meeting.
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.No. 4006, Rev. 0 2-O The inspection.results and unresolved items shall be documented in the inspection report as outlined in MC 0610. This is to include what was inspected, date of the work activity, a brief description of. the
. inspector's review or observation, and a brief statement as to why the item is unresolved. The c? ossification shall be consistent with the way the inspector characterized the finding in the exit meeting; otherwise, the licensee must be contacted.to inform them of the change and the. reason for the charge.
The format for documenting an unresolved item within the body of an inspection. report is as follows:
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The inspection report paragraph (s) which describe the technical or procedural matters that constitute the inspector's findings.
This information is followed by a sentence or paragraph of the following kind:
g is considered unresolved pending "The
- A succinct statement of precisely what about the findings is l
unresolved --
1 "the acceptability of the licensee's use of the XYZ h
Code.... " or "the alternate procedural controls...."
"the licensee's method of calculating ABC...."
I A statement as to who has the lead action in the next step of achieving resolution --
"pending licensee submittal to the region of...." or "pending discussions between the regional management and NRR....." or "pending further review by regional management."
1 For unresolved items identified during inspection of byproduct and source materiallicensees,)theresponsibile.vSectionChief(orBranchChiefinthe absence of sections is responsible-for tracking and timely (days or weeks, in most cases) closure of unresolved items.
The unresolved item is to be entered into the OIL for the facility.
Unresolved items should receive priority attention commensurate with the f
seriousness'ofthepotentialviolationsordeviations.-.[ NOTE:
instances where the inspector would simply be more reasonably assured of compliance if he performed additional inspections are suitable for classification as openitemsratherthanunresolveditems.] If the unresolved item requires action on the part of the licensee to resolve, the NRC letter transmitting the inspection report may request the licensee to provide a written N1 i
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AUG - A 1987 Regional Office Policy Guide No. 4006, Rev. 0 response. This will usually be necessary when it is important to establish the licensee's position on an issue. Those items which require NRC followup should be identified to the responsible organization in NRC, with an appropriate due date request, within two weeks of the end of the inspection. This request should be tracked by the regional ARTS system (RPG 0214).
The closeout of unresolved items needs to be well' coordinated between the inspector who irientified the item (originating inspector), and any other inspector who follows up on this item and proposes to close it. This requires sufficient inspection report detail to ensure the issue is understood.
D' C.
Action:
All regional inspection personnel should adhere to the practices described in this Policy Guide.
D.
Contact:
Any) questions or comments should be directed to the Training Officer (Ext.
195.
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Effective Date:
This Policy Guide is in effect when issued.
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NHC F ORM 103 THIS NUMBER MUST APPEAR ON ALL PACKAGES n 874 3 J,,,
,i AND PAPERS RELATING TO THIS ORDER N RCM 5101 PURCHASE ORDER i
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\\l II*07"277 3/0 POINT OF ISSUE: U.S. NUCLEAR REGULATORY COMMIS N
AALimCTON, TEXAS
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INSTRUCTIONS. See billing address, lower lef t corner of this form,
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PURCHASE ORDER PER YOUR OF DELIVERY ORDER UNDER CONTRACT NUMBER APeROeR4 r OmAuO wE N r j riN l94-20-26-51-2 8 & R NUMBER CONSIGNEE AND DESTIN ATION (MFDem -
v M M M TO M W M M DI 31X0200.f47 US Nuclear Regulatory Commission
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i TO S.ii.,1 Region IV. 611 Ryan Plaza Dr., Suite 1000
' Joe W. Rode. Ph.D.-
Arlington. Texas 76011 i
i li.E.B. Proidssional 0149 DEtiveRv F OB jetACe OF IN3eeCriON AND ACCEerANCe j DA rE 1604160 spital Parkway, Suite 200 Destination Sedford, Texas 76022
[DISCOuNr gAvMENr TERMS OcuvoRv Que as requested not PLE ASE FURN:SH THE FOLLOWING ON THE TERMS SPECIFIED ON BOTH SIDGS OF THIS SHEET AND ON THE ATTACHED. lF ANV. ExCEPT TH AT ANY SUCH TERMS WHICH MiG INCONSISTENT WITH THE TERMS OF ANY EXISTING FEDERAL CONTRACT OR AGREEMENT UNDER WHICH THIS ORDER IS PL ACED WILL NOT APPLY NEGOTIATED PURSUANT TO THE AUTHORITY OF 41 USC 252(C)(3L ITEM NO ARTICLES OR SERVICES OUANTITY uni f UNtf PRICE AMOUNT Commualcations and human sesources specialist services Estisated Cost 400.00 for NRC employees per Commission directed. Period of service is $pptentier 8. 1987 (or as requested) tlwough September 30, 1987.
kate: $100.00 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> session i
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i THIS IS A DIRECT FEDEkAL PROCUREMENT MD IS EXEMPT FAM ALL STATE. LOCAL. MD FEDERAL SALES AND USE TAIES
>E RSON TO CONTACT nEGAsDiNo THis ORDER TE L E PHONE l NUMBER TOTAL ARE A CODE Hancy holbrook, Purchasing Agent 317 860-8149
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,8 ARLINGTON, TEXAS 79011 AUG 111987 Regional Office Policy Guide No. 4002, Revision 0 TRAINING ISSUE: ENF0PCEMENT OF RECORD RETRIEVABILITY ISSUES A.
Purpose:
To inform the staff of the uniform practice to be followed in,the handling of the above issue.
B.
Discussion:
The failure of a licensee to produce a record required by regulations is a violation. There is, however, no comprehensive regulatory position on the time required to retrieve a record.
10 CFR 50, Appendix B, Criterion XVII, "QA Records" only requires that records be identifiable and retrievable.
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Retrievability of a record should be consistent with the safety significance of the issue involved. At a facility in operation, a record necessary to demonstrate safe operation or to respond to an emergency should be retrievable within minutes. Other records, such as at a facility under constriction, should be retrievable in a matter of days. For such records, the licensee should be informed during the inspection or at the exit that he may preclude a records related violation by submitting a requested record (s) prior to issuance of the inspection report.
In no case will an inspection report be delayed solely to permit the licensee to have additional search time. The same is true for open and unresolved items. A violation for the failure to retrieve a record at an operating facility which would be needed in the event of an emergency will not be withdrawn even if it is subsequently provided.
An inspector should use reasonable judgement when requesting a record. He should, in the course of an inspection, assure that the proper level of licensee management is aware of a record he has requested, but has not been provided. The records clerk may be knowledgeable in the retrieval of a record contained in the records vault, but will not necessarily be knowledgeable of the record process prior to the record arriving at the records vault.
At a construction facility, there will be different groups generating records such as construction, startup, and/or the operating organizations.
For example, construction may have completed an installation traveler and m
sent it to the records vault. Startu and/or operations could then initiate other installation traveler (p) for the same equipment as the i
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".,o Regional Office Policy Guide No. 4002, Revision 0 result of testing or operations so that the complete record of the system or component would not be apparent from the initial construction traveler and both sets of documents would have to be referred to in order to complete an inspection. At an operating facility, an inspector should always anticip(ate that there can be a delay for records to arrive at theFor example, records vault s).
records may be temporarily stored in approved containers at different locations within the facility. At some frequency, such records are subsequently forwarded to the records vault.
Except for actions taken to verify the integrity of selected records files as a test of the licensee's record system, it is not the best use of an inspector's time to search for and retrieve records personally.
The practices and policies contained herein (which are largely directed at utilization facility records) should also be used, as appropriate, in dealing with records related findings as a result of inspections of byproduct and source material licensees.
C.
Action:
All affected personnel are to adhere to the above practice starting on the effective date of this policy guide.
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D.
Contact:
Any questions regarding this pol n, guide should be directed to the 1
Enforcement Officer at extension 195.
E.
Effective Date:
Upon issuance.
Robert D. Martin Regional Administrator Distribution List C
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