NL-95-0053, Comment on Review of NRC Insp Rept Content,Format & Style. Insp Repts Frequently Not Appropriately Focused on Safety Issues

Comment on Review of NRC Insp Rept Content,Format & Style. Insp Repts Frequently Not Appropriately Focused on Safety Issues

ML20086D873
Person / Time
Site:	Crystal River
Issue date:	06/29/1995
From:	Ken Wilson FLORIDA POWER CORP.
To:	Meyers D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR28180, RULE-PR-MISC 60FR28180-00015, 60FR28180-15, NL-95-0053, NL-95-53, NUDOCS 9507110014
Download: ML20086D873 (5)

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U 51.. :.v Florida Power CORPORATION heen m toaar June 29, 1995 NL95-0053 U. S. Nuclear Regulatory Commission Attention: David Meyers, Chief, Rules Review and Directives Branch Division of Freedom of Information and Publication Services Office of Administration, Mail Stop T-6D-59.

Washington, D. C. 20555

Subject:

Review of NRC Inspection Report Content, Format, and Style

Dear Sir:

The Federal Register, Vol. 60, No, 103 (FR 95-13104) dated May 30, 1995, requested comments from the regulated industry concerning NRC inspection report content, format and style. Florida Power Corporation provides the attached as our comments.

Sincerely,

(

K. R. Wilson, Manager Nuclear Licensing KRW/RLM:ff Attachment CRYSTAL RIVER ENERGY COMP &X: 15700 W Power Une St . Crystal River, Florida 344284708 . (904) 7954486 A Fkwida Progress Com[nny 9507110014 950629 PDR G ADOCK 05000302 PDR

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'A.' Inspection Report Content ,

4 QUESTION: COMMENT

1. Focus on safety: 1.

a. Are inspection reports a. Inspection reports are frequently not ,

appropriately focused on safety- appropriately focused on safety issues. '

issues? Should report writers be required to articulate the safety ,

significance of each finding? *

b. Is _ the level of detail for a given issue generally commensurate with the  :

significance of that issue?

c. What threshold of significance c. Existing reports frequently do not use-should be used to determine whether or an appropriate threshold of significance.

not an observation should be documented in the inspection report?

Do existing reports generally use an '

appropriate threshold of significance?

d. Are reports, as currently written, too negative in their focus? Should d. Reports are currently too negative.  :

" equal time" be given to discussions of licensee strengths and successes? " Equal time" should be given to strengths !

If so, what criteria should be used to and weaknesses.

include such findings in inspection reports?

2. Supporting Details: 2.

a. Do inspection reports generally .

contain an appropriate level of detail i to describe technically complex i issues?

b. What level of detail should be included for describing an event when  ;

that event has already been described separately in a licensee event report? -

c. What level of detail should be used '

to describe inspection activities when little or no findings have resulted from those activities?  :

d. What are the costs and benefits of  ;

including, as enclosures to the.

report, all referenced material to d. The inclusion of all referenced i support report findings (e.g., material would not be cost beneficial, t licensee procedures, supporting

• calculations, or independent studies)? i i

i i

i

i QUESTION: COMMENT'

3. no comment.

3. Enforcement Issues:

a.' What information-should be included in inspection reports to support j

.taking enforcement actions?- l

'b. Are reports generally clear in  ;

stating the circumstances of the

~ violation (e.g., what requirement was -

violated, how it was. violated, who

-identified it, etc.)?

c. Is sufficient detail generally given to substantiate enforcement-related ' conclusions? .

d. Should all-minor and non-cited violations be documented in inspection i reports? What threshold should be used I to determine the significance of- 'j compliance items that must be  ;

documented?  :!

4.. Clear

Conclusions:

4. no comment.

a. Are report conclusions generally well-supported by facts?-Is the progression of logic generally clear?

b. Is a conclusion statement ~.

always necessary for each section of the report (e.g., when limited observations or findings were made in agiven. area)?

/

B. Inspection Report Format QUESTION: COMMENT

1. Consistency: 1.

a. Should inspection report formats be a. Inspection report formats should be consistent from region to region? What consistent from region to region.

benefits or problems would result from adopting a standardized report outline?

b. What are tile advantages and disadvantages of combined or integrated inspection reports (e.g.,

one report per six weeks, per reactor site, covering all areas)?

c. When is the use of "boilerplate" appropriate (i.e., standard phrases or sentences used from report to report to describe similar inspection methods, purposes, or conclusions)?

Should more or less boilerplate be used?

2. Readability: 2.

a. What features increase or decrease a ranort's readability or ef. Liveness in communication?

b. Do you prefer a narrative or a b. A "bulletized" appearance is preferred.

"bulletized" appearance?

3. Usefulness: 3. no comment

a. What features increase or decrease the efficiency of later efforts to retrieve information from a report (e.g., for SALP reviews, regional studies, or external reviews)?

b. Are there particular parts of the report that could be deleted without decreasing the report quality or ,

detracting from its function?

4. The summary should take a balanced ,

4. Report Summaries: What information approach with equal time given to  ;

should be included in a report strengths and weaknesses, summary? How should it be presented? ,

v:

• 5. no comment

5. Cover Letters: How might cover -

letters be modified to express more clearly the level of concern, or to  !

better convey a particular performance message to a licensee?

C. Inspection Report Style QUESTION: COMMENT

1. Style variations: In what ways do 1. no comment variations in writing style influence the effectiveness of inspection reports?

2. NRC style: Are there particular 2. no comment features of standard NRC style (e.g.,

consistent use of past tense or third-person form) that make inspection reports more readable? Less readable?

3. Tone: Are inspection reports 3. Inspection reports are generally not generally written in an appropriate written in an appropriate tone. Too many tone? adjectives and nouns are used in the negative, e.g. " failure to...".

Inspection reports should be written in a t neutral tone.

4. Grammatical Construction: Are 4. no comment inspection reports generally acceptable in sentence and paragraph construction? Do they give evidence of careful proofreading?

D. Additional Comments D. The whole emphasis in this survey seems to be how negative information can be In addition to the above specific presented so it can be easily retrieved .

issues, commenters are invited to and communicated. Inspection reports  !

provide any other views on NRC should provide a balanced view l inspection reports that could assist particularly since they are reviewed for i the NRC in improving their SALP input. The NRC needs to change the i effectiveness. culture of inspectors. The majority seem '

to believe the more negatively they write their report, the more it looks like they are being a tough regulator.

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