ML20086D884

Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style

ML20086D884
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	06/29/1995
From:	ENTERGY OPERATIONS, INC.
To:	Meyers D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR28180, RULE-PR-MISC 60FR28180-00008, 60FR28180-8, NUDOCS 9507110028
Download: ML20086D884 (5)

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David Meyers, Chief, Rules Review and Directives Branch Division of Freedom ofInformation and Publication Services Of6ce of Administration, Mail Stop: T6D59 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 A T fN.: Docketing and Service Branch

Subject:

Entergy Operations, Inc. Comments on Review of NRC Inspection Report Content, Format, and Style

Reference:

Ecdcral Recister Volume 60, Page 21180, dated May 30,1995 CNRO-95/00015

Dear Mr. Meyers:

The referenced Federal Recister listing invited comments on the NRC's proposed action.

" Comments on Review of NRC Inspection Report Content, Format, and Style." Entergy Operations the licensee for Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, i

River Bend Station, and Waterford 3 Steam Electric Station has reviewed the Federal Recister notice and offers the following comments for your consideration.

We believe a fundamental reexamination of the purposes of these inspection reports is necessary.

What is the purpose of the report?

. Is it to report all the activities that the inspector does at the plant site?

. Is it a record of ali the open and closed inspector items? If so, why is this detail necessary in the Public Document Room before the issue is clearly denned and 'leveloped?

. Does it serve another purpose other ih m record keeping?

- Is it an evaluation oflicensee performance?

- It is written in sal.P fonnat. Is it a n'ini SAI.P? Does it give Eeld inspectors too much power? The inspection report is the vehicle that is used to innuence utilities to take actions or make commitments that may not be required by NRC regulations.  ;

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Mr. David Meycrs l l June 29,1995 I CNRO-95/00015 l Page 2 of 3 l

NRC inspection reports which contain subjective evaluations dilute the purposes of the SALP process. The mini SALP report process is causing the inspector to rate each item that he sees.

These are mini value statements that are totally subjective. While NRC has made process improvements to the defined SALP process to address many industry concerns, by not changing the underlying inspection reports, many of the same problems persist there.

The inspection report should speak to the licensee and should focus on issues that enhance operating safety performance in a level of detail to provide an adequate context to clearly define safety significance or regulatory perspective. Where violations or apparent violations are noted, the regulatory basis should be clearly identified. Over reliance on general citations such as 10 l

CFR Part 50, Appendix A (General Design Criteria) or Appendix B (Quality Assurance Criteria) should be discouraged.

NRC cover letters for transmittal ofinspection reports should carefully track the factual findings in the inspection itself to avoid reaching unsupported conclusions in an effort to " send a message" to the licensee. Caution should be exercised in an inspection report when characterizing an item as a " management" deficiency or a " programmatic" problem. These terms are not well defined and involve highly subjective assessments. It is important that documents available for public review maintain a balanced, factual perspective. Not all inspection reports meet this standard.

The attachment to this letter provides additional comments.

Entergy Operations appreciates this opportunity to comment on the content, format and style of inspection reports.

Sincerely, h

DD/LAE/baa Attachment cc: (see next page)

r.

., Mr. Dxvid Meyers '

r June 29; 1995 CNRO-95/00015 -

Page 3 of 3 '

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Y cc: - Mr. R. P. Barkhurst' Mr. J. L. Blount -

- Mr. L. J. Callan

. Mr. J. F. Colvin Mr. S. D. Ebneter

- Mr. E. J. Ford Mr. C. R. Hutchinson

- Mr. G. Kalman u Mr. K. M. Kennedy L Mr. J. R. McGaha Mr. R. B. McGehee Mr. P. W. O'Connor Mr. C. P. Patel

= Mr. J. E. Tedrow Mr. W. F. Smith Mr. D. L. Wigginton Mr. J. W. Yelverton Central File (GGNS)

Corporate File [ ]

DCC (ANO)

NDC (RBS) -

Records Center (W-3) i i

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,g :. 4 Mr. David Meyers June 29,1995- -

CNRO-95/00015 ATTACHMENT ADDITIONAL EOI COMMENTS ON NRC INSPECTION REPORTS l

e Halancing of Strengths and Weaknesses [cf A.1] - Inspection reports are for the most part negative and should provide additional focus on positive actions noted during the inspection [ keeping in mind that inspectors are looking for process deficiencies when they perform an inspection and not the ' good things' in a program].

Additionally, the cover letter to an inspection report is intended to reflect the NRC -

management position of the report. Those aspects that are contained in the body of the inspection report which are positive are not typically reflected in the cover letter.

If the negative aspects are the primary messages perceived by NRC management, then the NRC's conclusions will be predominately negative in the SALP report.

.- Format and Detail [cf A.2] - It has been noticed that inspection reports have changed format toward a SALP format and the level of detail is reduced. However, these  ;

reports tend to selectively provide a greater level of detail on some Level IV '

violations which have little safety significance. The discussion should be consistent with other findings in the report and provide a summary of the information.  !

e Safety Significance [cf A.2) - When violations are cited, the safety significance of the issue should be clearly characterized. Currently, the safety significance of a violation is not discussed or clearly depicted.

e Requested Response Information [cf A.3] - Detailed information in inspection report responses should not be required for Level IV Notices ofViolation (NOV). A brief one page description of the reason and immediate corrective actions for the specific condition should only be requested. NRC follow-up inspections provide an opportunity to review the licensee's documented actions on the subject NOV for final acceptance and closure. This improvement in requested response information will provide for effective utilization oflicensee resources and reduce the number of commitments issued in a licensee's submittal.

• Report Format [cf Hj -Inspection report formats should be consistent from region to region.

• Performance Based Inspections [cf D]- All routine inspections performed by the NRC should be performance based inspections. Each area inspected should have clearly defined performance based criteria summarized in the report. The inspector should then focus his findings on performance issues rather than compliance based findings with no safety significance. - Compliance based inspections do not provide a ,

good reflection of t he performance and maturity of the licensee. This approach would also be consistent with the NRC's performance based philosophy as reflected in the maintenance rule, graded QA, etc. >

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Mr. David Meyers

- June 29,1995 '

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• Inspection Report Processing [cf D]- Options should be made available and used for -

the electronic processing of the inspection report and the licensee's response. The standards being established under the NRC electronic information exchange pilot

. program should be utilized when available. j i

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