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UNITED STATES4gy ^ 7, NUCLEAR REGULATORY COMMISSION i/,Q*

.j WASHINGTON. D. C. 20555*

3*'Ea Yg; % j

'"**DEC 7 194

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MEMORANCUM FOR: Clemens J. Heltemes, Jr. , DirectorOffice for Analysis and Evaluation

of Operational Data

FROM: Richard C. DeYoung, DirectorOffice of Inspection and Enforcement

SUBJECT: STUDY OF THE NEED FOR Afi INDEPENDENT AGENCYTO INVESTIGATE INCIDENTS AT NUCLEAR POWER PLANTS

By memorandum dated November 16, 1984 to the Executive Director for Operationsand to others, you requested coments on a draft report of the subject studywhich was prepared by Brookhaven National Laboratory. We have reviewed thedraft report and have coments and questions on the degree to which the factualinformation in the report supports Brookhaven's conclusions. In general, thedraft report does not seem to base its conclusion (that an independent officereporting directly to the Commission is needed) on specific problems identifiedwith the existing NRC organization.

Our specific comments and questions are enclosed.

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/-c ard D ung, Directorffice I pection and Enforcement

Enclosure: Ccmments on the BNL Study

cc: w/ enclosureW. J. Dircks, EDO V. Stello, DEDR0GRH. Denton, NRRJ. G. Davis, NMSSIE DirectorsIE Branch ChiefsJ. M. Taylor, IED. P. Allison, IEA. W. Dromerick, IER. W. Woodruff, IE

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Contact: R. W. Woodruff, IE~

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Enclosure-

COMMENTS ON THE BNL STUDY

1. Early on the report should provide the context within which an office ofnuclear safety or a nuclear safety board would function. To do that, thereport should present a concise description of the responsibilities of theprincipal regulatory offices of NRC, the relationships between them, andtheir relationships with licensees. The report should describe theseresponsibilities and relationships as they are now and as they would beafter the creation of a safety office or board. Section 4.2, on page 124,presents a cursory description of NRC responsibilities. The sectionshould be rewritten and repositioned. At a minimum, the report shouldstate that

.(a) NRR and the Regional Offices are responsible for and do issue andamend operating licenses and technical specifications for commercialnuclear power plants after performing the reviews required by Title10 of the Code of Federal Regulations;

(b) Operation of commercial nuclear power plants within. the constraintsof their licenses and technical specifications ensures that anadequate safety margin exists to preclude the release of fissionproducts to the environs;

(c) IE and the Regional Offices are responsi.ble for and do assure thatcommercial nuclear power plants are operated in compliance withlicenses and technical specifications;

(d) 10 CFR 50.72 requires that licensees promptly report to the NRCOperations Center via the Emergency _ Notification System any operating

|evint or condition indicative of a significant degradaticn in safety;'

(e) IE is responsible for operating the Operations Center cortinuouslyand does make a record of each notification received;

(f) l'0 CFR 50.73 requires that licensees submit written Licensee EventReports describing and analyzing events that are significant tosafety and any operation or condition prohibited by the plants'technical specification;

(g) The resident inspector assures that noncompliances are reported;.

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(h) The Regional Offices, IE, and NRR are each responsible for and doreview, on a timely and coordinated basis, event notificationsreceived in the NRC Operations Center and Licensee Event Reports;

(i) In the event thar in emergency condition develops, the NRC staffs theOperations Center with teams of personnel with expertise in areassuch as Reactor Safety and Radiological Assessment and it activates -

the Emergency Management Team to assure that appropriate protective . .

action recommendat,io,es_are made- -

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(j) Members of the _ Reactor Safety, Radiological Assessment, and otherteams are from NRR, IE, and other NRC offices and are on call;

(k) AE00 is responsible for and does review selected event notificationsand Licensee Event Reports for identification of generic trendsrelative to safety;

(1) Based on notifications, reports, and analyses of events, IE issues(1) information notices to advise utilities of events that may bepotentially generic and (2) bulletins, for events of greater safetysignificance, requiring licensees to correct safety problems whichcould lead to' a similar event or to submit information so that NRCcan detemine the need for further action to prevent a similar event;and ,

(m) Licensees are responsible for the safe operation of their plants andare subject to enforcement actions ranging from letters of admonitionto revocation of licenses.

2. On page 125, in Item a) of Section 4.3, Event Investigations Improvements,the report states that after an accident, the utility operating staffbecomes overwhelmed by waves of investigators from various groups, includ-ing NRC offices (IE, NRR, AEOD and regions), INPO, and EPRI/NSAC. If this

is true, then creation of the proposed office of nuclear safety mayexacerbate this problem rather than relieve it as claimed. To ensure thatit does relieve this problem, the report should address the impact on, andthe need for realignment of, rel?tionships between principal NRC officesand licensees that would result from the creation of an office of nuclearsafety.

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3. In Item a) of Section 4.3 and elsewhere, the report states that too manyindependent investigations tend to overlap, interfere, and make factfinding and determination of cause difficult. No examples were found inSection 2.6, Examples of Significant Event Investigations, to support thisnotion. In fact, conclusions a) through g) in Section 2.6.8 suggest theopposite. Further, it should be noted that NRC is the only organizationinvestigating events from the standpoint of a regulatory agency with nocommercial bias. Other organizations that investigate events are basical-ly industry or industry-supported groups. Within NRC, there is verylittle duplication or interference in event evaluations. In-depth,long-term studies of operational events for patterns or trends are doneonly by AE00. Other NRC groups may provide information or recommendationsto AE00 on long-term studies, patterns, or trends; but they do not performsuch studies. Because of immediate and short-term concerns, NRR reviewsevents from the standpoint of safety significance on the particular plantwhere an event occurs and to determine the need for licensing actions onthat plant or other pia'nts. IE reviews events to detemine the need forand to prepare generic comunications (either a bulletin or an.information"

notice). Daily comunication via a telephone conference call between NRR _and IE ensures that there is not duplication of effort and that informa- -

tion is shared by all offices. - The Regional Offices, ha~ving representa-tives at plant sites are relied on to collect facts concerning events.

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Information is shared among several groups, but the groups do not doduplicative work, nor do they interfere with one another.

4. Section 2.6.8, in Item a) on page 71, under Event Investigation Improve-ments, states that "at present there is no organization with sole respon-sibility for performing the investigation of significant events with theprimary focus of determining probable cause" and continues in this vein inthat section and on page x of the Executive Summary. From the point ofview of organizational entities that are the size of the NRC Offices ofNRR, IE, and AE00, and the Regional Offices, the statement is true butvery misleading. The Operations Center is part of IE and is staffedaround the clock by IE and, when on alert, is staffed by the variousoffices within NRC. The function of determination of cause is absolutely.and unequivocally essentfal to the Operations Center to ensure the contin-uing health and safety of the local public during and following an event.Lines 5 through 8 on page x of the Executive Summary state that "while theNRC, licensee, and equipment vendors all investigate major events, eachparty tends to focus on its own area of responsibility and not necessarilyon the determination of cause." The statement may or may not be true oflicensees and vendors. It is certainly not true of the Operations Center,and these and like sections of the report should be corrected.

5. Item f) on page 127 of Section 4.3 states, in essence, that there is aneed to identify which officers of NRC have the authority to issue ordersfor actions such as shutdown and to authorize restart following an assess-ment of an operational event. Such orders are coordinated between officesand emergency response teams. We do not believe that this has been aproblem; however, if it has, then an example should be cited. Item f)also states that "this affects how an event investigation is carried out."If this~ is true, it should be so demonstrated. Further, Section 2.1.4,'

Regional Offices, states on page 20 that the power to restart a plantafter a significant event seems to rest jointly with NRR and the RegionalAdministrator. Depending on the significance of the event, authorizationto restart may require extensive review by all of the principal regulatoryoffices of the NRC with authorization to restart being decided by theCommi ssi c'n. Further, the licensee has certain obligations under thelicense and the technical specifications, including review by the plant'ssafety committees.

6. The report does not adequately explore, or fully develop, the differencesbetween the obligations of the FAA/NTSB and NRC during and after an ,. -

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accident. NRC can and does provide support to the licensee after anaccident is initiated and before it is ended. Further, NRC has postaccident obligations to prevent or mitigate continuing hazards to thepublic and insults to the environment. After an aircraft accident is

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initiated, FAA rarely has an opportunity to mitigate the impact of thataccident on the public. For a nuclear accident, the plant conditions andthe actions taken to correct or mitigate the event must be determined assoon as possible so that protective action recomendations can be aseffective as possible. For this reason NRC maintains the OperationsCenter; has a management emergency officer always on call; has ReactorSafety, Radiation Assessment, and other teams to man the Operations Centerin an emergency situation; and conducts periodic training and drills.This information ought to be presented, in part, in Section 2.2.1,,Emergency Class of Events, and referred to in other sections whereappropriate.

7. Section 2.4.3, Incident Investigation and Analysis of Significant Events,addresses work by INP0. One of the examples on page 38 discusses ingressof high temperature water into auxiliary feedwater pumps and the conse-quences thereof. The report does not recognize that the problem wasidentified by AE00, as well as INP0; that AEOD prepared a case study; andthat IE issued Information Notice 84-06 on January 25, 1984

8. Section 2.4.2, INPO and NSAC Reporting System, on page 3S describes SERs(Significant Event Report) and SOERs (Significant Operating ExperienceReports) that are produced by INP0 and NSAC. These reports are availableto the industry, generally available to NRC, and are not available to the-public. A discussion of the advantages and disadvantages of the lack ofpublic availability of INP0 and NSAC reports and evaluations should beincluded in Section 2.4, INPO-EPRI Practices.

9. There are problems with tone and uneven treatment of issues that lead tothe following comments:

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(a) ' Section 2.4, INP0 and EPRI/NSAC Practices, reads like an INP0/EPRIpress release when compared to sections cn NRC practices;

(b) Contrary to the statements in Section 4.2, INP0 and HSAC ReportingSystem, on page 36, there is no indication of INP0 or EPRI/NSACinvolvement, if any, in signficant event investigations for theexamples given in Section 2.6;

; (c) Section 2.4.2 states that 76 SERs and 9 SOERs were written in 1983.~ Section 2.1.3, Office of Inspection and Enforcement should state that

IE issued 84 information notices and 8 bulletins to licensees during,! the same period; and

(d) Section 2.1.3 should also discuss the fact that IE screens for safety

significance all daily (e)eports and preliminary notifications from ther

regions, 10 CFR 50.55 construction deficiencies 10 CFR 21 reportsfrom vendors 10 CFR 50.72 Imediate Notification Reports, and 10 CFR

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50.73 Licensee Event Reports., ,

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10. On page 20, Section 2.13, Office of Inspection andInforcement (IE),3states that the Events AnaTysis~ Branch is responsible for identifyinggeneric problems requiring a quick response and that the branch decides

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whether action is required. The branch, in fact, interfaces with otherbranches in IE and NRR before making a recomendation on issuance of aninformation notice, bulletin, or other response.

11. Page viii of the Executive Summary addresses reports to NRC by licenseesthat result in immediate and short-tem investigations by NRC. TheExecutive Summary addresses 10 CFR 50.73 reports (Licensee Event Reports)but not 10 CFR 50.72 reports (Immediate Notifications). The OperationsCenter receives and the Events Analysis Branch screens approximately 4000Immediate Notifications per year. These notifications are the basis for

* NRC immediate and short-term actions.

12. Section 2.2, Event or Incident Definition, states on page 21 that thekinds of events that must be reported to NRC are given in 10 CFR 50.72.Section 2.2 also should refer to 10 CFR 50.73 and should be carefullywritten to distinguish between reports to the Operations Center via theEmergency Notification System and Licensee Event Reports submitted by mailto the Regional Directors.

13. Section 2.1.3, Office of Inspection and Enforcement, she'ld state underu

Information Notice on page 18, should state that AE00, as well as NRR andhMSS may recommend issuance of IE bulletins and information notices.

14. The discussion of the IE/NRR morning telephone conference call in Section2.1.3, under Events Analysis Branch of IE on page 19 is not correct.Although the real-time safety of the particular plant involved in an eventtakes precedence over other considerations, a major, fundamental purposeof the conference call is to assign the actions required to determine thecause of each event and the need for generic actions on other plants.

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15. In Section 2.1.3, under Bulletin on page 18, the report states that one ofthe criteria for issuing a bulletin is that" timely information is neededby the NRC for further assessment of a particular situation." This ismisleading. A bulletin is not issued to determine if an event is signifi-cant but, rather, to determine whether other plants could have the sameproblem and to ensure that actions are taken to minimize the probabilityof a similar event occurring at another plant. A bulletin may alsorequest information to determine the need for further actions to prevent asimilar event. Bulletins are issued in response to an event after theevent has been determined to be significant, rather than to determine ifthe event is significant. !

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16. Section 4.2, NRC Responsibilities, on page 124 states that "IE investiga- Itions are specifically focused on enforcement and potential rule viola- )tions." The statement is ircomplete. The Events Analysis Branch and theEngineering and Generic Communications Branch review events to identify |

the cause and determine actions to prevent recurrence.'

17. Throughout the report, the acronym "0RAR" should be "0RAB," Operating-

Reactors Assessment Branch. .

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d, ,w . GA-4gg y g M SECOND DRAFT

November 28, 1984,

04<,4 M

[MEMORANDUM OR: C. J. Heltmes. Jr.

FROM: R. C. DeYoung

SUBJECT: STUDY OF THE NEED FOR AN INDEPENDENT AGENCY TOINVESTIGATE INCIDENTS AT NUCLEAR POWER PLANTS

By memorandum dated November 16, 1984 to the Executive Directorfor Operations and others, you requested comments on a draftreport of the subject study which was prepared by Brool: havenNational Laboratory. We have reviewed the draft report, and wedo have comments and questions on the degree to which the factualinformation in the report supports Brookhaven*c conclusions. Ourcomments and questions are attached.

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cc/w attachments: $'2 (- .,, ,, ,

- b'Dircks, EDO

Stello, DEDROGRDenton, NRRDavis, NMSSIE DirectorsIE Branch ChiefsAllison, IEDromerick, IEWoodruff, IE

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Attachment

COMMENTS ON THE BNL STUDY

1. The report early on should provide the context within whichan office of nuclear safety or a nuclear safety board wouldfunction. To do that, the report should present a clear,concise, crisp description of the responsibilities of theprincipal regulatory offices of NRC, the relationships betweenthem, and their relationships with licensees. The report shoulddescribe these responsibilities and relationships as they are nowand as they,.would be after the creation of a safety office orboard. Section 4.2, en page 124, presents a cursory descriptionof NRC responsibilities. The section should be should berewritten and repositioned. At minimum, the report should statethats

(a) NRR and the Regional Offices are responsible forand do issue and amend operating licenses andtechnical specifications for commercial nuclear powerplants after performing the reviews required by Chapter10 of the Code of Federal Regulations;

(b) Operation of commercial nuclear power plantswithin the ccnstraints of their licenses and technical

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specifications assures that an adequate safety marginexists to preclude the ' release of fission products tothe environs;

'' (c) IE and the Regional Offices are responsible for and

do assure that commercial nuclear power plants areoperated in compliance with licenses and technicalspecifications;

(d) In the event that a licensee inadvertently orotherwise operates in noncompliance with the technicalspeci#4 cations and in certain other operating events,10 CF J4f.72 requires that licensees promptly report tothe NRC Operations Center via the Emergency Notifica-tion System those operating conditions that are not incompliance with the technical specifications ;

(e) The Resident Inspector assures that noncompliancesare reported- 1

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(f) IE is responsible for operating the Operations |

Center continuously and does make a record of each I

notification received; )3073 )

(g) 10 CFR 78' requires that licensees submit writtenLicensee Event Reports describing and analy:ing eventswhich are significant to safety;

(h) The Regional Offices, IE, and NRR are each respons-ible for and do review on a timely and coordinated

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basis event notifications recei ved in the NRCOperations Center and Licensee Event. Reports;

(i) In the event that a potential safety problemdevelops, the NRC staffs the Operations Center withReactor Safety. Radiological Assessment, and otherteams to determine the cause of the event and to assurethat remedial actions are adequate;

(j) Members of the Reactor Safety, RadiologicalAssessment, and other teams are from NRR, IE, and otherNRC offices and are on call;

(k) AEOD is responsible f or and does review selectedevent notifications and licensee event reports foridentification of generic trends relative to safety;

(i) Based on notifications, reports, and analyses ofevents, IE issues bulletins requiring licensees tocorrect safety problems which could lead to a similarevent or submit information so that NRC can determinethe need for further action to prevent a similar event;and

(j) licensees are resonsible for the safe operation oftheir plants and are subject to enforcement actionsranging from letters of Admonition to revokation oflicenses.

I2. On page 125, in Item a) of Section 4.3, Event InvestigationsImprovements, the report states that, after an accident theutility operating staff becomes overwhalmed by waves of inves-tigators from various groups, including IE, NRR, Regions, AECD.INPO. and EPRI/NSAC. If this is true, then creation of the-

02N proposed office of nuclear safety may exacerbate, rather thanrelieve this problem, as claimed. To assure that it does relievethis- problem, the report should address the impact on and. the,

need for realignment of relationships between principal NRCoffices and licensees that would result from creation of an

| office of nuclear safety._

< - - -3. In Item a) of Section 4.3 and alsewhere, the report states+

that too many independent investigations tend to overlap, inter-fere, and make fact finding and determination of cause difficult.No examples were found in Section 2.6, Examples of SignificantEvent Investigations, which support this notion. In fact,Conclusions a) thru g) in Section 2.6.8 suggest 'thw opposite.

g -o/L Futher, it should be noted that NRC is the only organization iIinvestigating events from the standpoint of a regulatory agencyIwith no commercial bias. Other organizations which investi. gate

events are basically industry or industry supported groups.Within NRC, there is very little duplication or interferrence inevent evaluations. In-depth, long-term studies of operational

, events for patterns or trends are done only be AEOD. Other NRC

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groups may provide information or recommendations to AEOD onlong-term studies, patterns, or trends: but they do not perform

,such studies. Because of immediate and short-term concerns, NRR

reviews events from the standpoint of safety signifiance on the

' particul ar plant where an event occurs and to determine the need|for licensing actions on that plant or other plants. IE reviews

events to determine the need for and to prepare generic commun-ications (either a bulletin or an information notice). Dailycommunication via a tele phone conference call between NRR and IEensures that there is not duplication of effort and that informa-tion is shared by the offices. The Regions, having representa-

tives at plant sites, are relied on to collect facts concerning

events. Information is shared among several groups, but the

groucs do not do duplicative work nor lo they interfere with oneanother.

I~ 45 Section 2.6.8, in Item a) on page 71, under Eyent Investiga-

ti20 IO9C9EeGeOts. states that "At present there is no organiza-tion with sole responsibility f or perf orming the investigation ofsignificant events with the primary focus of determining probablecause" and continues in this vein here and on page x of the

Executive Summary. From the point of view of organi:ationalentities that are the " size of the Office of NRR. the Office of

ggd IE, the Office of AEOD, and the Regional Offices, the statementhis true but very misleading. Tne Operations Center is part of

IE. is staffed arcund the clock by IE and, when on al er t , is

staffed by the various offices within NRC. The function of~

determination of cause is absolu'tely and unequivocally essentialIo the Operations Center in assuring the continuing health andtsafety of the local public during and following an event. Lines5 thru E on page : of the Executive Summary states "...that whilethe NRC, licensee, and equipment vendors all investigate majorevents, each party tends to focus on its own area of responsi-

bility and not necessarily on the determination of cause." Thestatement may or may not be true of licensees and vendors. It is

certainly not true of the Operations Center, and these and likesections of the report should be corrected.

f 5. Item f) on page 127 of Section 4.3 states, in essence, thatthere is a need to identify which officers of NRC have the

authority to issue orders for actions such as shutdown and to

authori:e restart following an assessment of an operational

* event. Such orders are coordinated between offices and emergencyresponse teams. We do not believe that this has been a problem;

2 however, if it has, then an example should be cited. Item f)D)p - also states that "this affects how an event investigation is

; carried out." If this is true, it should be so demonstrated.iFurther, Section 2.1.4, Regional Offices, states on'page 20 thatthe power to restart a plant after a significant event seems to

rest jointly with NRR and the Regional Administrator. Depending

on the significance of the event, authori:ation to restart ,may

require extensive review by all of the principal regul'atoryoffices of the NRC with authorization to restart being decided bythe Commission. Further, the 1.icensee has certain obligations

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hunder the license and the technical specifications, includingreview by the plant's safety committees.

#~ LEI' The report does not adequately explore or fully develop the: differences between the obligations of the FAA/NTSB and NRC

' during and after an accident. NRC can and does provide support.to the licensee after an accident initiates and before it isended. Further NRC has post-accident obligations to prevent ormitigate continuing na:ards to the public and insults to theenvironment. After an aircraft accident is initiated, FAA rarelyhas an opportunity to mitigate the course of the accident. -For a

DOP nuclear accident, cause must be determined as soon as possible,so that remedial action can be as effective as possible. Forthis reason NRC maintains the Operation Center; has a managementemergency officer always on call; Reactor Safety. RadiationAssessment, and other teams to man the Operations Center when analert is declared; and conducts periodic training and drills.This information ought to be presented in part in Section 2.2.1,

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Emergency Class of Events, and referred to in other sections_,where appropriate.

7. Section 2.4.3, Incident Investigation and Analysis ofSignificant Events, addresses work by INPO. One of the enampleson page 58 discusses ingress of high temperature water intoE ggg auxiliary feedwater pumps and the consequences thereof. The

does not recogni:e that the problem was identified by| reportAEOD, as well as INPO; that AEOQ orepared a case study: and thatIE issued an information notice in January, 1954.

mS. Section 2.4.2, INPO and NSAC Reporting System, on page 55,

describes SERs (Significant Event Report) and SOERs (SignificantOperating Experience Report) which are produced by INPO and NSAC.These reports are available to the industry. generally available

Wb to NRC, and are not available to the public. A discussion of the L~gCadvantages and disadvantages of the lack of public availabilityof INPO and NSAC reports and evaluations should be included inSection 2.4, INPO-EPRI Practices. I

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9. There are problems with tone and uneven treatment which leadto the following comments:

r~ Ai (a) Section 2.4, INPO and EPRI/NSAC Practices, reads y

D&JE 'like an INPD/EPRI press release when compared to 6_ sections on NRC practices;

f(b) Contrary to the statements in Section 4.2, INPO'and NSAC Reporting System, on'page 36, there is no

CCwE k indication of INPO or EPRI/NSAC involvement, if any, in,significant event investigations for the examples given' in Section 2.6;

FC(c) Section 2.4.2 states that 76 SERs and 9 SOERs were,gg written in 1983. Section 2.1.3, Office of Inspection L' Enforcement, should state that IE issued 84 information

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notices and 8 bulletins to licensees during the sameperiod; and

e-(d) Section 2.1.3 should also discuss the fact that IE

jt screens all daily reports and preliminary notificationsy from the regions for safety signifiance, as well as 10

CFR 50.72 and 50.73 reports.

: r~10. On page 20, Section 2.1.3, Office of Inspection and

Enforcement (IE), states that the Events Evaluation Branch isresponsible for identifying generic problems requiring a quick

(f>5b response and that the Branch decides whether action is required.The Branch, in fact, interfaces with other branches in IE and NRRbefore making a recommendation on issuance of an information_ notice, bulletin, or other response.

11. Page viii of the E::ecutive Summary addresses reports to NRC|by licensees which result in immediate and short' term investiga-

pC tions by NRC. The E::ecutive Summary addresses 10 CFR 50.73reports (Licensee Event Reports) but not 10 CFR 50.72 reports

(Immediate Notifications). The Operations Center receives and gL )NCc #,.*dc Ithe Events Analysis Branch screens approximately 4000 Immediate ys Pv,

g; Notifications per year. These notifications are the basis for ,,,L 4e"

4 93 - NRC immediate and short-term actions. ggg'. 73

12. Section 2.2. Event or Incident Definition, states on page 21 A ',t 6cL_

that t'he kinds of events that mus be reported to NRC is given inSection 2.2 shoul,t yg, rs.d also refer to 10 CFR 50.73 and10 CFR 50.72. g'y g

CE ' 4should be carefully written to distinguish between reports to theOperations Center via the Emergency Notification System andLicensee Event Reports submitted by mail to the RegionalDirectors.

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T 13. Section 2.1.3, Office of Inspection and Enforcement, shouldstate under Igigtmatigg Ngticg on page 18 that AEOD, as well as

COV NRR and NMSS may recommend issuance of IE bulletins andinformation notices.__

14. The discussion of the IE/NRR morning telephone conferencecall in Section 2.1.3, under Evenig Analygig @canch gi IE, on

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gcJl)page19 is not correct. Although the real-time safety of the

particular plant involved in an event takes precedence over otherconsiderations, a major, fundamental purpose of the conference; call is to assign the actions required to determine the cause ofeach event and the need for generic actions on other plants.

15. In Section 2.1.3, under gulletin, onipahe'18, the reportstates that one of the criteria for issuing a bulletin is that... timely information is needed by the NRC for further"

assessment of a particular situation." This is misleading. ACC g, bulletin is not issued to determine if an event is significant

but, rather, to ensure that actions are taken on other plants tominimize the probability of a similar event occurring on anotherplant. A bulletin may also request information to determine the

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need for further actions to prevent a similar event. Bulletins

are issued in response to an event after the event has been "" |

determined to be significant and not to determine if it is |

significant.

P~165 Section 4.2, NRC Responsibilities, states on page 124 that"IE investigations are specifically focused on enforcement and

g potential rule violations." The statement is incomplete. The

Events Analysis Branch and the Engineering and Generic Communica-yg ,

tions Branch review events to identify the cause and determine

actions to prevent recurrence.

! 17. Throughout the report, the acronym, ORAR, should be ORAB,,

CD'''' Operating Reactors Assessment Branch._

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