IR 05000346/1978027
| ML19256A299 | |
| Person / Time | |
|---|---|
| Site: | Crane, Davis Besse  |
| Issue date: | 10/24/1978 |
| From: | Creswell J, Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19256A298 | List: |
| References | |
| TASK-TF, TASK-TMR 50-346-78-27, NUDOCS 7811290326 | |
| Download: ML19256A299 (5) | |
Text
.-
.
,
s
.
.*
.
-
s
.
.
U.S. -NUCLEAR REGULATORY COMMISSION OFFICF OF INSPECTION, AND ENFORCEMENT REGION ITI Report No. 50-346[/78-27[
~
License No. NPF-3 Docket No. 50-346
-
.
Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse Nuclear Plant, Unit 1 Inspection At: Davis-Besse Site, Oak Harbor, OH Inspection Conducted:
September 5-8, 1978 rg
,.
l.
/
-
'
Inspector:
J. S. Creswell l /t.V2 9/ 78'
Th IU/b4/78 Approved By:
J. F. St-reeter, Chief
'
Nuclear Support Section 1 Inspection Summary Inspection on September 5-8, 1978 (Report No. 50-346/78-27)
Routine, unannounced inspection of selected startup Areas Inspected:
tests performed during Cycle 1B power escalation testing, review of previously identified unresolved items and review of high Pressure Injection performance during the September 24, 1977 event.
The inspec-
,
tion involved 24 inspector-hours onsite by one NRC inspector.
Of the three areas inspected, no items of noncompliance were Results:
identified.
,
.
.
I917 i69
_
m W
7h/2?03 M
'
'
.
-
'
,
,
_
.
- <
.
.1 F
.N
.
DETAILS
.
1.
Persons Contacted
- T. Murray, Station Superintendent
- G. Novak, Superintendent, Power Engineering
- J. Lenardson, Manager, Quality Assurance
-
- F. Miller, Power Engineering
.
- J. Buck, Operations Quality Assurance Manager
- W. Green, Administrative Assistant The inspector also interviewed other licensee employees including members of the technical and operations staff.
interview.
- Denotes those attending the exit
) Review of High Pressure Injection Performance Du' ring Septemb'er -241
'
2.
- 1977 Eventi involved the subsequent f ailure of; The Sep.tember 24, 197.7, event
'~
.the power. operated relief valve and the initiation of~high pressure injectipp. The event _ was previously described ~in an inspec
. report.-
(
cated floy in. leg 2-1 of. the High Pressure Injection System..whereas process, computer printouts indicated a flow greater than 75 GPM The times that
'
existed in this leg during the same time period.
the 75 GPM low flow alarms were cicated on the four injection legs are listed below:
Elapsed Time From Hour Minute Second Lcgt SFAS Initiation (second.-)
37
2-1
21
49 l-2
21
50 1-1
21
14 2-2
This data indicates a 40 second dif ference between the time the low flow alarm cleared on Leg 2-1 until the alarm cleared on Leg 2-2.
To, explain the time. delay in Leg 2-2-compared with l
i
, Leg 2-1,. thezilicensee hypothesized.that a stop-r. heck va ve n-1 Leg 2-2 was.'stickingi';due' to the valve being manually seated
=
'
following the last local leak test.
Since Leg 2-1 also serves as the path for normal makeup injection, the stop-check valve
.
line had been cycled open during normal makeup prior to
-
in that 1/
IF Inspectic' Report No. 50-346/77-32.
1917 170
'~
_2_
-
_
-
..
.
o
-:-
experience sticking.
.
the September 1977 event and therefore did not Discussions with the valve manuf acturer. revealed.that a dif fere
[ pressure _ontheorder_of30-40p'si..isrequired.toopenLthistypeUsing data reco v'alve after it has been manually sealed.
flow the September 1977 event,.the licensee determined that the low a reactor coolant pressure of approxi-alarm cleared on Leg 2-1 at mately 1550 psi whereas loop 2-2 cleared at approximately 1400 psi.
A copparison of computer data for an event which occu
,
The results of this _ analysis will be reviewed during a future inspec-1978-tion and the item is_ considered to be unres,olved.
The(computer _printoutsLalso, indicated that_during t
^
.
~
containment spray SFAS_ logic returned to normal.which indicates, The' blocking occurred' prior; to turning off: the -
t they were blocked..
high : pressure, injection pumps. and the. discovery off the cause_ of,
~
The:-licensee is_ reviewing the_oper-
,the loss of' reactor coolant.
Cator' actions o'f blocking th'e SFAS logic and securing high pressure ilinj ection lto' determine if 'dif f erent actions woul'd be advisable in
~
This matter the' future should a similar set of conditions arise.
is unresolved.
The inspector reviewed the results of TP 205.07, High Pressure Review of the test data indicates (-
Injection System SFAS Test.
the acceptance criteria of HPI flow greater than 665 GPM at 475
'
PSIG reactor pressure was met.
Review of Corrective Action Associated with Noncompliance 3.
As a result of an item of noncompliance 1 issued in conjunction with
rod-drop testing the licensee initiated a review of test procedures The to determine if other test deficiencies were not documented.
licensee's review revealed that the following deficiencies had not been properly documented:
TP 800.01 - Shield surveys indicated excessive radiation Facility Change Request a.
levels in area of main steam line.77-337 issued.
TP 800.14 - Turbine-Reactor Trip Test at 75% resulted in b.
load steady state data not recorded for 30%
'
TP 800.12 - Unit
In addition, certain steam line c.
and 100" power levels.
pressures did not meet acceptance criteria.-
-
Deficiency reports have been filed documenting these items.
'
2/
LER NP-30-78-01.
50-346/78-06.
,
-3/
IE Inspection Report No.
1917 171
-
- 3-
.
. *.
.
.-
.i
.
3.
(
.
.
Review of Selected Power Escalation Testing for Cycle IB 4.
Review of the results of the Pseudo Ejected Rod Test revealed a measured ejected rod worth of 0.55% AK/K versus a predicted worth Since the' difference between the predicted and of 0.85% AK/K.
measured values exceeded the acceptance criteria by greater than The
+ 20% the vendor was contacted to resolve the deficiency.
vendor stated the results we,re acceptable and explained that the
,
difference was due to variation ~s in the rod worth curve analyzed.
discussed the discrepancy with NRR and had no further The inspector questions.
Review of the results of zero power physics testing regarding moderator temperature coefficient revealedameasuredvagueof AK/K/ F versus a predicted value of 0.5 x 10-AK/K/ F.
-4 0.7 x 10 The measured value was less than the Technical Specification limit As a result of the relatively large value measured,
of 0.9 x 10 the technique to extrapolate the coefficient to the 100% pcwer value
.
'
was modifieg. The modified extrapolation yielded a value of-0.04 x 10~
AK/K/ F.
Since the value represented only a slightly negative coefficient at 100% power the vendor recommended another A measurement at measurement prior to escalation above 95% power.
approximatgly 90% power resulted in an extrapolated value of-0.2 x 10~
AK/K/ F.
The inspector has no further questions about this item.
Power imbalance detector correlation results were reviewed.
Original correlations performed for Cycle 1 were performed with a relationship of an incore to excore axial offset ratio of 1.
For Cycle 1B the vendor has required a relationship of excore A
axial offset equal to 1.25 times the incore axial offset.
vendor representative states the change is based on prior experi-ence and an analysis performed in Lynchburg.
The inspector has no further questions about these areas at this time.
5.
Further Review of ICS Tuning at Power As previously reported,4/ Sections 7.5.1 and 7.5.2 of TP 800.08 were removed by procedure modification.
Further review of the The area revealed no actual test data was available for review.
the testing requirements had been met during licensee stated that normal operations.
The Plant Superintendent stated that acceptance The inspector criteria as delineated by the procedure had been met.
,
has no.further questions about this item.
.
.
_4./ IE Inspection Report No. 50-346/78-17.
s
,
-'-
-
1917 172
~..
-
> *.
.
'
.
.
Further Review of Unit Load Steady State Testing 6.
the acceptance criteria Further review of this area revealed that for turbine header pressure was exceeded at 0% and 15% power levels.
Enclosure 7 of the procedure which detailed the acceptance criteria As for the testing was removed by procedure change in March 1978.
reported in Paragraph 3, deficiency reports regarding this matter have been filed.
~
-
.
7.
Unresolved Items
.
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of Unresolved items are identified in Para-noncompliance or deviations.
graph 2.
8.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) on September 8, 1978 to summarize the findings of the inspection.
interview the licensee. discussed ainew transient 29, 19775/
,During the exit
.
_
b canalysis the vendor had performed regarding the Novem er.'The'ne
.
tap and that a previous ievent.
('
- to 32 inches below the lower level instrument calculatlon furnished to.the, inspector dated March' 8, 1978 was in
~
In addition. the.new -analysis;is probably nonconservative >
since it!does not include the effects of makeup flow:which differed error.
,
from the standard conditions used in the analysis.
.
s
',
.
5/
IE Inspection Report No. 50-346/78-06.
.
.
-
-
1917 173-5-
i a.) k',
.
/
UNorgD STATES
'*
March 16, 1977 NUCLEAR REGULATORY COMMts0 ION SECY-77-138
W ASHINGTON. D. C.
20555 INFORMATION REPORT
-
.
For:
The Comr issioners From:
Ernst Volgenau, Director, Office of Inspection and Enforcement Thru:
Executive Director for Operation Subject:
LOCATING NRC INSPECTORS NEAR REACTOR SITES -
TRIAL PROGRAM Purpose _:
To forward the IE Evaluation of the Trial Inspection Program
!
and to inform the Comission that IE proposes to proceed with planning to locate inspectors near certain reactor sites.
j Issue:
Does locating an NRC inspector near a reactor site result in a more effective and efficient inspection program?
Discussion: The current NRC reactor inspection program is carried out by inspectors who are assigned to an NRC Regional Office which may be located as much as several hundred miles from a reactor site where inspections are to be performed.
Undei this arrangement, implementation of the program requires ins'pector, to travel between the Regional Office and the reactor site at various intervals of time and to remain on-site for various lengths of time.
A concept of " resident inspection" was pro-posed in 1974, in which an inspector would be assigned full time to a location near reactor sites rather than being assigned to a Regional Office.
A trial program which applied this proposed resident inspection concept to inspection of operating reactors was developed to provide a basis for evaluating the concept.
This trial inspection program was implemented at two locations, including four reactor sites and five reactors during 1974 and was planned to extend for two years in order to obtain information necessary for an adequate evaluation of the trial program.
The principal benefits expected from the concept of resident inspection being evaluated were as follows:
Increased on-site inspection time, Improved NRC awareness of the facility activities, and Increased inspector efficiency.
',.y
'
CONTACT:
h
,
B. H. Grier, IE l9]/
l ~f 4 (\\L/
- m 49-27356
_- g g/ h \\
c
'
~78//A;?o2 /Y'
,
.
s
'
,
.
Realization of these benefits would provide NRC with increased assurance of the safe conduct of licensed activi-ties.
The major concern associated with the resident concept was the potential for loss of inspector objectivity because of the inspector's close day-to-day association with the licensee.
Factors to be included in evaluation of trial program effective-ness and efficiency were delineated prior to commencement of the program.
The principal factors to be evaluated were the following:
I Impact on safety of operations, Accomplishment of the inspection program, Budgetary impact, Impact on inspector, and Licensee reaction.
Trial Program Description:
The trial inspection program for operating power reactors was initiated in June 1974 by stationing the first " resident inspector" at Two Rivers, Wisconsin, with responsibility for inspection of the Kewaunee and Point Beach Unit No.1 and Unit No. 2 facilities.
In September 1974, an inspector was stationed at Benton Harbor, Michigan, and assigned inspection responsibilities for the Palisades and D. C. Cook Unit No.1 facilities.
The scope of authority and responsibility assigned the trial program inspectors was consistent with that assigned inspectors operating from the Regional Office.
The management and supervision of the trial program was under the Region III Office (Glen Ellyn, Illinois). The trial program was terminated in October 1976.
Evaluation:
The Office of Inspection and Enforcement has now completed its detailed evaluation of the trial program. The results of this evaluation are documented in Enclosure 1.
As a basis for the evaluation, the evaluation team received input from the licensees, trial program inspectors, and regional supervision; made first-hand observations at the sites; and reviewed the inspection reports and other documentation associated with conduct of the trial program.
~~ ~
1917 175
%
m
.
,
.
.
.
Summary of Conclusions:
IE has concluded that the trial program has demonstrated that the concept of locating inspectors near reactor sites is viable, and under certain circumstances, is the preferred method of inspection.
The specific conclusions are as follows:
1.
Inspector effectiveness was improved through increased direct observation of facility operations.
2.
!
Because of inspector location, NRC awareness of facility status was enhanced due to increased on-site time and g
ability to respond to facility problems.
3.
Inspector acceptance by the licensee was enhanced, resulting in easier access to facility records and increased inde-pendence of inspection effort.
4.
Licensee effort in support of the NRC inspection process was reduced.
5.
Licensee management attention to NRC requirements was enhanced.
6.
There is no significant budgetary impact associated with the inspection concept.
7.
Application of the inspection concept is restricted by the availability of qualified inspectors and candidate locations.
8.
There was no indication of loss of inspector objectivity associated with the trial program.
9.
From the standpoint of increasing the effectiveness of the NRC inspection program, locating an NRC inspector near the reactor site is the. preferred alternative for:
-- A cluster of three or more operating reactors within a radius of approximately 25 miles.
-- A single or multi-unit facility during the preoperational testing /startup phase.
(917{76
-,
p
.
-
s
,
.
.
10. Nothing was identified in the trial period which suggests that the inspection concept is not applicable to reactors under construction.
Imolementation:
The Office of Inspection and Enforcement proposes to implement a program of locating inspectors near power reactor facilities in the testing and operations phases.
The effectiveness of the concept will be continuously evaluated during the imple-mentation and any necessary corrective action, which may include termination of the program, will be promptly effected.
g Commencing in fiscal year 1978, IE plans to station inspectors at five locations.
In fiscal year 1979, inspectors will be stationed at 13 locations.
Full implementation of the concept described in this paper is planned by fiscal year 1981 with inspectors at 35 locations.
The reactor facilities which are presently candidates for this program are identified in Enclosure 2.
It should be noted that each power reactor facility becomes a candidate as it begins the activities associated with preoperational and startup testing.
To fully evaluate the feasibility of locating NRC inspectors near power reactor facilities under constructiori, IE proposes to initiate a two-year trial program in fiscal year 1978.
Candidate facilities for this trial program are identified in Enclosure 2.
Related Study:
Further study is underway to identify how much and what kind of reactor inspection provides adequate protection of the public and the environment.
This study includes an assessment of full-time federal employee in the reactor control room. The results of this assessment will be available in sufficient time for Comission consideration in developing a response to the petition for rule making which inctdes this issue (SECY-77-51 ).
Other related issues under study include:
more direct measure-ment versus records review by NRC inspectors, the use of mathematical and statistical techniques in the inspection program, application of techniques of other regulatory organiza-tions, etc. Although complete information on some of these 1917 iT7
n
.
L
.
.
issues may not be available for a year, it is hoped that enough information will be available in the next few months in order to have an impact on the formulation of the fiscal year 1979 budget.
This information will be presented to the Commission by July.
In the meantime, planning will proceed for locating inspectors near reactors.
Both the planning and the fiscal year 1978 initial implementation will be structured so as not to conflict with subsequent Commission decisions regarding the petition and the fiscal year 1979 budget.
!
f'
i
..
U,
!
, G _m ;.', ;c./
,
t
..: --- c -
,,
Ernst Volgenau Director Office of Inspection and Enforcement
Enclosures:
.
1.
Evaluation of the Trial Inspection Program 2.
Candidate Sites DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations Regional Offices Secretariat
.
1917 178
.
.h
-
..
'
.
.
January 28, 1977
-
-
-
.
,
EVALUATION
.
OF THE TRIAL RESIDENT INSPECTION PROGRAM
.
,
-TsFFICE OF INSPECTION AND ENFORCEMENT U.S. NUCLEAR REGULATORY COMMISSION
.
.
Evaluation Team g, Blackwood, Reactor Inspection Specialist, W3.,Jy m of Reactor Inspection Programs
'
Hall, Chief, Engineering Support Section,
-
R5;$hp,;m of Field Operations, Region IV
'
, Jordan, Chief, Engineering Support Section.
C4Q[g,;,f tn of Field Operations, Region III o
Reviewed by
/ttot6 b
0 l>
JJmes H. Sniezek, ChiefJ L1ght Water Reactor Programs Branch
.
4/ k [
..
Approved by:
2.,,e a_.
/Boyce/li. Grier, Director Division of Reactor Inspection
Programs 1917 179
.
.
-
ENCLOSURE 1
-
,4 m
?
i
.
.
.
.
.'
.
.
.
'
.
TABLE OF CONTENTS Section Page
~
1.
Abstract...........'..........
2.
Introduction...................
.
3.
Trial Program Description
'
............
3.1 Execution...................
'
3.2 Evaluation Basis
...............
.
4.
Trial Program Results
..............
l 4.1 A
REGION III NON-RESIDENT INSPECTORS
, TO COMPLETE PERIODIC AND REFUELING MODULES (766 -- JANUARY-SEPTEMBER 1976)
TWO UNIT SINGLE UNIT FACILITIES FACILITIES AVERAGE TIME
-
-
MODULE AVERAGE-TIME PER UNIT FREQUENCY NUMBER SHORT TITLE'
(HOURS)
(HOURS)
A 35701 Quality Assurance
13
-
A 36700 Organization & Administration
4
,
A 37700 Design
5 A
38700 Procurement
4 A
39700 8ecords
4
!
A 40700 Audits
5 I
'
A 41700 Training
5
,
A 41701 Requalification
5 A
42700 Procedures
10 A
42702 Fire Protection
6 A
54700 Cleanliness
2 A
56700 Calibration
7 A
56701 Calibration
7 R
60705 Preparation for Refueling
7 R
60710 Refueling
15
,
A 61700 Surveillance
5
,
i A
61701 Surveillance
-
-
j A
62700 Maintenance
14 I
R 62701 Refueling !!aintenance
4 j
Q 71710 Operations 33*
18*
!
R 71711 Refueling Operations
3
l R
71712 Refueling Operations
3
-
.'
A 71720 LSSS
~ 3 R
72700 Refueling Startup
4 Q
90710 Operations 12*
12*
-
.
,
[
A 90711 Operations
1 l
A 90730 Annual Report
1
,
!-
- for 3 Quarters
-
's-g-
._ !
1917 189
~
-
-.-
.
'
j.
.
-
l!.
~
TABLE 4.1.2
>
i.-
COMPARIS0N OF ACTUAL TIME BY RIP-1 INSPECTOR WITil AVERAGE TIME BY OTilER
!!
REGI0tl III IfiSPECTORS TO COMPLETE PERIODIC AND REFUELING MODULES
-
.
(766 DATA -- JAflUARY-JULY 1976)~
.
l
'
'i'.l Point Beach Unit 1 or 2 Kewaunce
.
'
i Module ACTUAL / AVERAGE ACTUAL / AVERAGE
!
'
Frequency Number Short Title (llours)
_
(flours)
,
l A
35701 Quality Assurance
/
9
/
l A
~16700 Organization & Administration
/
24
/
.
- '
'
A 37700 Design
/
l
-
A 36700 Procurement
/
!
-
A 3970G Records
.
-
-
-
I A
40700 '
Audits
-
-
'
,
A 11700 Training
/
10
/
l A
41701 Requalification
/
-
'
A 42700 Procedures TO
/
16
/
1's
,
E'
A d2702 Fire Protection
/
24
/
A 51700 Cleanliness
/
.
-
.
A 557C0 Calibra tion
/
7
/
u.
'
l A
56101 Calibra tion
/
2
/
'
R 60705 Preparation for Refueling
/
10
/
j ;
i R
60710 Refueling
/
19
/
!l
,
A 61700 Surveillance
/
7
/
-
-
'
A 61701 Surveillance l
-
-
['
A 62700 Main tenance
/
9
/
R 62701 Refueling Maintenance
/
11
/
!
.
I
Q 71710 Opera tions
/
21
/
R 71711 Refueling Operations
/
9
/
--
!
<
R 71712 Refueling Operations
/
10
/
I A
71720 LSSS
/
15
/
-
'
'
N R
72700 Refueling Startup
/
8
/
I
Q 90710
' Opera tions
/
20
/
l
_
A 907!1 Operations
/
-
.
le A
90730 Annual Report
/
c j
.
-
'!
TOTAi.
162
/ 163 239
/ 170 t
'
'
- '
Average per inodule 6.75 6.79 13.28 9.44
!
Efficiency" 1.00 0.71 Conbined Efficiency
'.090
,'
- rrri. irncy emealy nvoraan timo ner inodule for NON-RIP Inspector vs. RIP actual time.
.
y
^
- --
.
,
,
'
TABLE 4.1.3 COMPARISON OF ACTUAL TIME BY RIP-2 INSPECTOR WITH AVERAGE TIME BY OTHER
-
REGION III INSPECTORS TO COMPLETE PERIODIC AND REFUELING MODULES (766 DATA -- JANUARY-SEPTEMBER 1976)
Cook Unit 1 Palisades RIP NON-RIP RIP NON-RIP ACTUAL / AVERAGE ACTUAL / AVERAGE Module Frequency Number Short Title (Hours)
(Hours)
/
-
-
A 35701 Quality Assurance A
36700 Organization & Administration
/
-
/
A 37700 Design
-
A 38700 Procurement
/
-
A 39700 Records
/
6
/
A 40700 Audits
/
-
-
A 41700 Training
-
/
.A 41701,
Requalification
-
A 42700 Procedures
/
-
-
A 42702 Fire Protection
-
A 54700 Cleanliness
/
10
/
A 56700 Calibration
/
-
a A
56701 Calibration
/
-
"
/
.R 60705 Preparation for Refueling
-
'
/
R 60710 Refueling
-
/
A 61700 Surveillance
-
-
A 61701 Surveillance
-
/
A 62700 Maintenance
-
/
R 62701 Refueling Maintenance
-
Q 71710 Operations
/
36
/
12
/
R 71711 Refueling Operations
-
/
R 71712 Refueling Operations
-
e-A 71720 LSSS
/
-
-
/
R 72700 Refueling Startup
-
-
N Q
90710 Operations
/
23
/
-
A 90711 Operations
-
A 90730 Annual Report
/
10
/
_
e 203
/ 117 220
/ 135
~
TOTAL 15.62
/ 9.00 14.67
/ 9.00
.
Average per module 0.58 0.61 Efficiency *
0.60 Combined Efficiency
- Efficiency equals average time per module for NON-RIP Inspector vs. RIP actual tim '
..
.
1'.'
-
.
i
-
n
-- The inspector's frequent presence was a constant reminder to the licensee of regulatory requirements.
I
.
-- During the test and startup period,, the inspector's frequent contact with the licensee reduced NRC/ licensee interface i
problems during the startup program.
4.2 Inspection Manpower Utilization Since one of the major benefits from the trial Resident Inspection Pro-gram was expected to be greater on-site inspection effort, daily activ-
,
ity time records were maintained by both inspectors.
An evaluation of these records after one year showed tha,t they were consistent with the RMS data records for the RIP inspectors; therefore, daily activity
.
records were discontinued, and RMS records were utilized in this evalu-j ation.
A comparison between the RIP inspectors and other inspectors was accomplished using RMS data.
These data are tabulated in Tables
,
P 4.2.1 and 4.2.2.
Table 4.2.1 delineates the RIP-1 inspector's time in each of the selected RMS categories.
Evaluation of these data
,
against inspector records indicated good agreement overall; however, it was observed during the interim evaluation that no differentiation between in-office inspection time and in-office inquiry followup time was being accomplished by the RIP-1 inspector.
This differentiation
was made during the subsequent year.
The time data for the RIP-1 inspector were somewhat affected by approximately three weeks of lost time which resulted from a serious medical situation which the resident inspector experienced early in the RIP trial program; however, this
,
pertubation does not appear to affect the overall conclusions.
Table 4.2.1 also delineates the RIP-2 inspector's time in the same
categories. The categories of Travel Time (C00) and All Other Time
.
}
for the RIP-2 inspector were significantly affected by the multiple moves of the RIP-2 field office.
Initially, the office was located a
'
more conveniently to the D. C. Cook plant and to an all-weather freeway between the two sites such that travel time was minimized, j
The final office location was less conveniently located thus resulting
.
in increased travel time to and from the two plant sites.
- Within the category of All Other Time, the time for the RIP-2 inspector was higher as a direct result of lost time involved in coordination of the office moves and resultant administrative burden.
A part-time
secretary was provided for the RIP-2 office for the second year in an attempt to reduce this time category; however, no significant i
reduction was evident.
Table 4.2.1 also compares FY 1975 manpower time distribution for the RIP-1 and RIP-2 inspectors with similar time categories for other selected inspectors.
For the purpose of this_ evaluation, seven
!
-
- 12 -
!
-t 1917 192
-
.
-
.
,-
.
.
-
!
additional Region III inspectors with similar work histories were selected.
Their RMS profiles were tabulated in Column 3 of Table 4.2.1.
A selection of RMS data for 27 selected inspectors in all regions with j
similar work profiles was accumulated and is tabulated in the fourth column of Table 4.2.1.
From this table, it' appears that:
,
.
'
a.
A significant reduction in in-office, docket-related effort, other than in-office inspection effort, resulted from the reduced documentation practices for the RIP-1 inspector.
i
This reduction was not observed for the RIP-2 inspector since
the status and problems of his facilities did not permit the abbreviated method of documentation.
b.
An increase of approximately 50% in the combined on-site and off-site inspection effort relative to other typical inspectors
.
l apparently resulted from the closer proximity to the facilities l
and resultant greater flexibility of both of the resident inspectors in scheduling on-site time.
c.
On-site inspection effort was increased by greater than 50%
over selected non-RIP inspectors; however, for the RIP-2 inspector, this was only an increase of 28% over this 1974 performance.
This is explained in part by the prior assign-ment of the inspector to the Zion facility (preoperational and startup status) which is located within 50 miles of the
,
IE:III office. This benefit' appears to be directly attributable to the' resident inspector concept.
-
d.
Travel time remained essentially consistent with other categories of inspection.
This indicates that a reduction in travel time for the resident inspector was not attained as anticipated.
This unexpected result is due to the application of inspection time employed by both inspectors.
They usually spent part of the day on-site and part of the day in the office, with com-muting time to the sites included in the normal eight hour i
work day as Travel Time, whereas the other IE inspectors nor-
.
mally commute to the site during non-regular hours.
e.
A reduction in "all other" type activities was apparent for the RIP-1 inspector.
This was because the inspector had not been assigned additional work activities as he would have been in a regional office.
Consequently, he had devoted
.
essentially all of his time to docket-related activities, i
i As noted above, the multiple office moves for the RIP-2 in-spector affect these data, and thereby preclude a firm con-
.
clusion.
-
,
'
.
[
1917 (93
~
'
-
-
&a
!
.
.-
.
.
.
.
.
,
For comparison purposes, Table 4.2.2 was developed to show the FY 1974 performance of the resident inspectors relative to the selected
,
Region III inspectors.
It is noted that the inspectors were essentially equivalent in all categories to the other inspectors during the FY-74 period; however, as previously noted, the RIP-2 inspector had a typically high on-site inspection effort.
This tends to confirm the observation that significant time benefits to the inspection program have accrued as a result of the location of the inspectors in the proximity of the facilities.
Tables 4.2.3 and 4.2.4 were prepared to evaluate the relative inspection i
effort for the resident inspectors and the support inspectors (those
'
based in the Regional Offices that performed reactor safety inspections at the RIP facilities).
As shown, the support inspection effort for the RIP-1 facilities was roughly equivalent in total to the resident i
inspection effort. This appears reasonable for facilities in relatively stable operation.
On the other hand, for the RIP-2 facilities, the
support effort was approximately double the resident effort apparently as a result of the dynamic conditions at these two facilities.
(D. C.
i Cook Unit No. I was in test and startup for the first year; Palisades was experiencing operational difficulties, primarily with steam generator tube corrosion and with core internals vibration).
These data are significant in that they indicate a potential area for further benefit from the resident concept if the resident inspector were given
-
responsibility to perform selected inspections currently assigned by Region III to specialist support inspectorc, and to follow-up and closeout inspection findings of the specialist inspectors, t
'
,
l
.
O
%
!
.
t
'
.
.
.
1917 194 q
_
.
..
.
.
.
.
.
'
.
TABLE 4.2.1 MANPOWER TIME * DISTRIBUTION FY 1975 AND 1976'
Other Resident Other Inspectors Inspector.
Region III from Other
' RI P-1 RIP-2 Inspectors Regions ITO In-office docket-related efforts 23.9 28.0 33.6 31.9
,
ITW On-site inspection effort 27.2 36.7 18.2 20.4 l
l ITX Off-site inspection effort includes in-office 22.5 2.5 6.9 7.6 C00 Travel Time 9.2 6.5 8.2 8.0 B00 Professional Improvement 4.9 1.6 4.7 7.5 Investigations / Inquiries 0.9 1.4 2.5 2.2 Absence 10.6 7.2 11.5 9.3 All Other 0.8 16.1 14.4 13.1 Percentage of which was non-regular hours 3.5 8.0 9.7 12.3
.
!
'
-
- All values are in perce.it of total time recorded in RMS file
!
,
-
'
.
-
.
i e
- 15 -
.
_
1917 195 w
.
.
'.,
'
t
,
!
'
TABLE 4.2.2
,
i MANPOWER TIME * DISTRIBUTION
'
'
FY 1974
,
,
Other i
Resident Inspector **
Region III
,
' RIP-1 RIP-2
_ Inspectors ITO In-office docket-related efforts 32.6 34.8 35.6 ITW On-site inspection effort 18'.6 28.5 16.7 e
ITX Off-site inspection effort, i
including in-office 17.6 6.3 8.0 000 Travel Time 7.1 9.2 7.1 B00 Professional Improvement 11.5 6.0 9.0 1.4 1.1 Investigations / Inquiries
-
Absence 10.4 5.8 10.7 All Other 2.4 8.0 11.7 Percentage of which was non-regular hours 10.7 11.3 11.7
.
All values are in percent of total time recorded in RMS file
. **
Prior to becoming a resident inspector
.
-
%
.
.
- 16 -
jgjJ
{g6
-
i
..
..
,
e
'
.
TABLE 4.2.3 SUPPORT MANPOWER TIME * DISTRIBUTI0ft - RIP-1 FY 1975 Afl01976 Point 8each Units 1 and 2 Kewaunee
' Support Resident
~ _ Support Resident ITO In-office docket-related efforts 825.3 648.5 552.1 372.4 ITW On-site inspection 465'.3 668.5 390.5 537.0
,
ITX Off-site inspection, inc10 ding in-office 84.0 627.3 162.5 345.3 C00 Travel Time
'198.0 140.7 221.7 180.3 Total 1572.6 2085.0 1326.8 1395.0 Total Support 2899.4 Total Resident 3480.0
- All values are manhours as recorded in the RMS file for reactor safety inspections
.
9 O
%
.
e
- 17 -
.
1917 197
.4
l
-
i
,-
.
,
i
.
.
TABLE 4.2.4 SUPPORT MANPOWER TIME * DISTRIBUTI0ft - RIP-2 i
FY 1975 Afl01976 D. C. Cook Unit 1 Palisades **
Support Resident Support Resident ITO In-office docket-related efforts 1729.0 61 2.8 1732.1 510.0 ITW On-site inspection 1025.0 947.4 993.3 489.9 ITX Off-site inspection, f
including in-office 304.0 60.0 81.0 60.3 r
C00 Travel Time 441.5 48.8 496.3 116.4 Total 3499.5 2209.0 3302.7 1185.6 Total Support 6802.2 Total Resident 3394.6
- All values are manhours as recorded in the RMS file for reactor
safety inspections
- Assigned to RIP-2 inspector on January 8,1975
-
.
@
%
.
- 18 -
-
19}7
$9b
I
.-
i I.
I k
4.3 Safety of Operations a.
Compliance History
!
Evaluation of the safety of operations in a comprehensive sense
!
was not quantitatively assessable.
Certain aspects related to safety of operations which could be quantified were included as elements in the previously established guidelines for RIP cost benefit analyses.
The significance of these quantified results must necessarily be qualified by judgment.
Other aspects of safety of operations could not be quantified, and, as such, their treatment has been limited to subjective evalu-ation.
A relative degree of regulatory aw'areness of safety related issues was quantified by comparing the enforcement records of trial program facilities with those of other licensed
'
power reactor facilities.
O Tabulated in Tables 4.3.1 and 4.3.2 are the enforcement records for the five RIP facilities and five facilities chosen because they were the previous facilities inspected by the assigncd RIP inspectors.
Data are tabulated in Table 4.3.1 indicating the number of items of noncompliance identified during the year prior to the resident inspection program at the RIP-1 facilities, the number identified at the inspector's previously assigned facilities during the year prior to the start of RIP, and the number identified during the two years of RIP at all facilities.
Table 4.3.2 presents similar data for RIP-2.
Evaluation of the data from these tables indicates that there has not been a significant change in noncompliance history at these facilities.
Analysis of contributing factors in the observed levels of noncompliance revealed two countervailing effects which could be only evaluated based on judgment.
On one hand, increased inspector knowledge and awareness, discussed in Section 4.4, enabled the resident inspector to identify problems which could leau to future noncompliance.
In a preventive sense, the resident inspector took initiative to focus licensee manage-
.mnt attention on the potential for noncompliance that, in the absence of corrective action, may lead to citation.
The resident inspectors considered this preventive approach to be in the best interests of the NRC in enhancing the safety of op,eration instead of remaining silent until noncompliance had occurred and a citation could be issued.
Licensee management prerogatives to effect corrective action in advance were not considered abrogated
.
19 -
-
i
,
1917 199
~
,
d
_
.
.
lo n1 r1 A
t
5
ei
1
nn aU u
D se
.
i1 t1 i
Ct
8
i
1
dn
,
aU t
u r
.
Q o
per e
.
s e
n i.
n o
ht u
8
i ts a
1
t e
w c
fr e
oe e
i K
p t
s en n
si I
o
pf Y
h t
ro R
c n
u O
a e
pf T
e2 m
F S
B e
e I
t
6
g he H
ti
a th nn n
t T
iU a
r
N o
M od
E P
fe M
l r
E
-
a de C
P i
nd E
R I
. c ai L
O R
h s e
,s B
F c
e p n
A N
a i s eo T
E e1 t
l c B
i a i
E t
6
l Fs V
ti
i f i
I nn c o
T iU a
A o
f t
L P
r P
E d a mI R
e p oR n
r e
e r
e ef g s fr co c
o cf co i a o
nt n
i no n
s df a
)
aer a
ar s d e
i r4 irp i r i a a e n1
.
l o7 l p l a l e p
i3 pi p
r pe py y o a
mrY msa my m
l l
t y o pF o
e o
od s e bl c 'r y ct cn u v ou c
(
nr no ns no o e J
oas ot g or oc i d s
nee ncn ni ne v
ao yi ei f
s e s wt f
t fpr f
f r n m
o gi osu og og p o y1 e
nl nd n
n i
r t
sii si si si s t ot
.
I mrc m
y)
mr mr a
ts eua ett4 eu eu
'r t
su tdf tai 7 td td o i ig
)
)
i
~~
.
.;
.
,
.
TABLE 4.3.2 RELATIVE ENFORCEMENT HISTORY *
RIP-2 D. C. Cook Point Beach Point Beach Zion Item Unit l Palisades Unit 11 Unit 21 Unit 11
~
a.
Number of items of noncompliance identified during year prior to NA
b.
Number of items of noncompliance identified at inspector's pre-
5
-
vious facility during year prior to RIP (FY 74)
E n>
c.
Number of items of noncompliance identified during first year of
34
7 522
""
'
RIP (FY75)
d.
Number of items of noncompliance
.
identified during second year of
33
13
RIP (FY76)
,
1 RIP-2 inspector's previously assigned facilities.
2 Includes 19 citations developed as part of a special Management Inspection.
- }'
- Enforcement history was obtained from 766 File, and for the purpose of this report,
__.~
the period October 1 to September 30 for RIP-2 is considered the FY of interest.
)
N N
".
cD
-
.
'
..
.
.
.
'
.
because the resident inspectors refrained from suggesting courses of action.
Rather, they carefully limited their communication to problem identification and potential for noncompliance.
Follow-up inspection activity incident to licensee corrective action involved independent assessment by the resident inspectors.
On the other hand, the RIP advantages of more frequent observation of licensee activities, higher fractional time on-site, and the attendant greater depth of coverage in areas inspected, enhanced the resident inspector's opportunity to identify noncompliance.
l Thus, the value of quantitative assessment of data in Tables 4.3.1 and 4.3.2 is reduced to judgment regarding the significance of these countervailing effects.
A review of the inspection history for RIP did, however identify a benefit in that items of noncompliance identified by the in-spectors were rapidly resolved and closed out such that they did not require protracted followup.
As observed by the evaluation team in reviewing the inspection reports, and as indicated by the RIP inspectors, corrective action taken in response to identified items of noncompliance was verified by the inspector on a continuing basis.
The items were often resolved before the inspection report was issued.
This rapid closecut was an obvious result of the resident inspector's demonstrated capability for higher frequency of on-site visits.
Even though rapid closecut is not a direct
'
measure of facility safety, knowledge of the corrective action taken can have an indirect impact on safety through more timely and responsive licensee corrective action.
In the opinion of the resident inspectors and the evaluation team, the resident inspector capability for frequent access to the facility resulted in more constant licensee attention to identified problems and facilitated more rapid resolution thereof, regardless of whether associated acts of noncompliance had been committed or compliance history had been altered.
,
for reasons stated above, the conclusion that safety of operations at RIP facilities has not changed does not necessarily follow tne numerical data.
The qualitative assessment of the evaluation team was that safety of operation was enhanced through more constant regulatory awareness on the part of the licensees and higher visibility of the 1.1spector.
-
b.
Licensee Reporteble Events Pre-established evaluation criteria for reportable cccurrences
-
were accuracy of information provided by the inspector, elapsed time between inspector and regional supervision notification, and elapsed time to closecut or resolve.the occurrence.
i
-
'
<
.
1917 202
-
j
- 22 -
g
.. '
..
.
.
..
Evaluation of data for reportable occurrences reported to Region III by the inspectors revealed no significant change in elapsed time between notification from the licensee to notification of regional supervision, including cases having special significance, in which case notification was essentially immediate.
,
,
'
~
The remote location of the resident inspector and the attendant higher threshold for communication with his regional supervision resulted in the application of inspector judgment as to whether the significance of a particular event warranted an immediate report via telephone and expenditure of NRC resources by regional management.
In cases of special significance, such as the steam generator tube failure at the Point Beach facility, the resident inspector f
notified his regional supervisor immediately (at approximately 6:00 a.m.), prior to the resident inspector's departure from I
his home to the site.
.
In situations where, based on resident inspector judgment, the reportable occurrence did not warrant immediate notification of regional supervision, the cost of telephonic communication and time expenditure of regional supervision were saved.
Because of the proximity of the resident inspector, it was observed that:
-- Reportable occurrences could be more rapidly assessed as to significance based on the inspector's independent evaluation, and the inspector could verify the licensee's evaluation, resulting in more meaningful information flow to regional supervision; and
-- Events of special significance, many of which were not reportable occurrences, could be more rapidly evaluated
-
and corrective action verified without the problems and expense of dispatching an inspector to the site from the Regional Office.
Even though not always required, one of the inspectors (RIP-1) charac-teristicLlly evaluated all licensee event reports as soon as practical after initial notification, frequently closing out on-site inspectior of these items prior to receipt of th? licensee's written report.. The other inspector evaluated licensee event reports as reouired by the formal inspection program of IE Manual Chapter 2515, sucn that no benefit in this crea resulted.
(During the trial program,.MC-2515 required in-office screening of all reported licensee occurrences
.
-
- 23 -
.
19\\1 205 (
-
.
=
.
'
.
,
l
.
.;
t
-
'
and a quarterly selective sample inspection of licensee event reports.)
i Basing the inspector near the site has demonstrated that a potential benefit in this area can be achieved.
This early site evaluation
,
could benefit both the inspector and licensee, since data could be more readily available and time would not have dimmed the memories
-
!
of the individuals involved.
This is identified as a direct benefit of the RIP concept, both to the flRC and to the licensee.
'
4.4 Inspector Awareness
'
This evaluation parameter was selected to identify problems unique to a facility which are identified by the inspector independent of the reporting requirements of the licensee.
Examples of items identified by the RIP-1 inspector were:
Identification of a general problem for torque switch setting
a.
t and thermal overload protection for limitorque valve operators.
I'
b.
Identification of the impact of a backlog of administrative activities upon the ability to satisfy regulatory require-ments.
Identification of a problem not recognized by the licensee c.
with respect to a breaker failure.
d.
Identification and location of a bottomed-out pipe hanger.
Identification of a rod insertion limit procedural error e.
which resulted in incorrect operator information.
Similar examples of items, identified by the RIP-2 inspector were:
Improper fastening of cable identification tages in the contain-a.
ment ice condenser.
i b.
Identification of ice condenser anomalies to the Licensing Project Manager.
Discovery of a nitrogen bottle in containment, and a valving c.
error prior to the integrated leak rate test.
-
d.
Prevention of the licensee's violation of technical speci-fications regarding nuclear instrumentation operability requirement, liquid radwaste release limits, and flux tilt surveillance monitoring.
Identification of an inattentive guard.
e.
,
'
'
'
1917 204
-
- 24 -
-
..
i
..
..
.
i
.
f.
Implementation of vital area radiation zone controls.
.
In addition, because of his familiarity with the facility and his frequent visits, the inspector was able to expedite requested changes to the D. C. Cook Unit No.1 Technical Specifications prior to operating
.
license issuance through direct communication with the assigned
.
Licensing Project Manager.
Review of these items by the evaluation team indicated that these types of items are of a nature such that they may normally have been detected or performed by a non-RIP in-spector and their identification and correction prior to their be-
.
coming more significant was not necessarily a direct result of the frequent visits and greater inspection freedom afforded the RIP inspector.
Licensee management, regional supervision, and the resident inspectors all agreed that the resident inspector concept did enable the inspector
to gain far better knowledge of the physical plant and the licensee organization.
Although the specific examples above could not be
'
l attributed directly to the presence of a resident inspector, the resident inspector was more effective in identifying problems such as:
a.
Equipment which is operable, but whose reliability based on frequency of breakdown may be degraded.
b.
Administrative policies or practices that are or are becoming deficient.
c.
Need for preventive measures (improvement) which if not taken in advance of significant evolutions such as refueling, could result in future mistakes and noncompliance.
This acute knowledge enabled the inspector to channel his emphasis toward problem areas via independent inspection effort.
The resident inspector also knew individual operators and workers better, saw more of what went on day to day, and know how mainte-
,
nance was actually performed.
He could get down to the working level and use direct observation with understanding, specific technical knowledge, confidence and respect of licens_ee personnel.
,
Greater inspector awareness is not without potential cost.
Without effort to the contrary, the^ resident inspector could become involved i
in the licensee's decision making process.
The assigned inspectors guarded against this tendency by not recommending courses of action, but rather causing the licensee to discharge his responsibility.
Problems identified by the resident inspector were considered by the licensee who based any policy or program change on his own
,
analysis, not on recommendations of the resident inspector.
Circumvention
,
.
5-1917 205
~
,
,
,
.-
,...
.
'
.
of the licensee management because of the increased direct licensee employee contact is a potential cost.
On occasion the resident inspector became aware of problems before the plant manager.
This
'
was cause for some measure of licensee embarrassment, but regardless of who notified whom, improvement / correction was considered to be in the public interest and effectively served NRC objectives.
The higher level of inspector awareness and identification of more problems in case of a recalcitrant licensee was considered to be a factor in greater supervisory effort on the part of regional management.
In contrast, generally lower awareness of the non-RIP inspector in the case of recalcitrant licensees was thought to result in less supervisory effort expended because fewer problems would have been brought to their attention.
Regional supervisory efforts regarding recalcitrant licensees are more closely related
,
to the number of problems identified than to the resident vs.
i regional inspector mode of inspection.
4.5 Supervisory Effort An increase in effort was required from the Project Section Chief to supervise the resident inspectors when compared on a per inspector basis with non-resident inspectors.
This increase is attributed to reduced conrnunications flexibility and the necessity for additional review of inspection results documentation by the Section Chief.
A slight increase in Section Chief travel time in support of the resident inspectors relative to non-resident inspectors was also noted; however, this was not considered a significant increase.
Approximately equal effort was required by the Section Chief to supervise the inspection program of five reactor units under the routine program when compared to that required for the five reactor units under the RIP inspectors.
Three project inspectors were
,
assigned to perform and manage the inspection program at the five remaining reactor units, whereas twu were assigned for the five RIP inspected units.
The normal span of control for a Projects Section Chief of 5 to 8 inspectors should be decreased to a range of from 4 to 6 inspecterc
'
under a resident inspection prog.am due to the increased supervisory effort required; nowever, this ruductica in number of inspectors would be offset by the larger number of rcactor units inspected by a resident ir.spector.
4.6 Administrative and Support Functions l9
.
Table 4.6.1 cornpares the cost of administrative and support functions for resident inspectors with aquivelent costs for non-resident irist,ectors.
Review of these data on a per inspectnr basis reveals the following.
i
'l 2'i -
'
'
'
.
.
TABLE 4.6.1
,
.
COST COMPARIS0NS FOR RESIDENT INSPECTIONS ADMINISTRATIVE AND SUPPORT FUNCTIONS RIP-1 (Boyd)'
RIP-2 (Baker)
Non-RIP 0FFICE FACILITY AND EQUIPMENT RENTAL
,
Facsimile
$
76/ month
$
76/ month
$
1/ month Telephone (facsimile)
55/ month 32/ month 30/ month Telephone (verbal)
101/ month 161/ month
--
i Copy Service 30/ month 60/ month 25/ month Secretarial Service (1 day / week)
125/ month
--
--
Message Recorder (initial one-time cost of purchase 9/ month 11/ month
--
amortized over 2 years)
Office Space 125/ month 265/ month 80/ month Total Office Costs / Month 396/ month 730/ month 136/ month Total Office Costs / Year 4752/ Year 8760/ Year 1632/ Year TRAVEL COSTS Travel Cost / Inspector 1397.76 1383.24 3704.11
,
MOVE EXPENSES Inspector Relocation Costs 5551.00 5008.00 (to RIP site)
--
Office Relocation (to RIP) '
250.00 290.00
'
--
.
.
- 27 -
.
.
1917 207
-
.i
.
..
.
'
.
a.
Office facility and equipment rental costs exceeded the normal cost of office provisions by from $3120 (RIP-1) to $7128 (RIP-2)peryear.
b.
Travel costs for each resident inspector were less than the average travel cost per routine program inspector by approximately
$2130 per year.
-
c.
Reimbursed moving expenses for the resident inspectors averaged
$5300 each move.
Assuming reassignment every two years the annual cost due to moving would be approximately $5000 to $6000 per year per RIP inspection assignment.
d.
The cost of moving the resident inspection office facilities averaged $270 and if amortized over two years results in an annual added expense of $135.
This cost would be a one-time I
cost for each new RIP location.
Based on the above the net annual increased cost of maintaining a resident inspector compared to an inspector working out of the regional office could be expected to be approximately $8000 per inspector per year. Actual costs incurred above regional office based inspectors were $6245 (RIP-1) and $10,253 (RIP-2).
The major variable was cost of office rental and the use of part time secretarial help.
It should be noted that the higher office rental rate for RIP-2 was associated with a federal building which means the actual cost was from the NRC to GSA, i.e., intragovernmental.
The drawback to this apparent advantage was the requirement by GSA to utilize this vacant federal office even though it was less efficient for the resident inspecto_r than available privately owned office space.
A cost effectiveness comparison can be drawn between a resident inspector and the average of the non-resident inspector by applying the increases in program accomplishment (Section 4.1) to the above net costs associated with resident inspection.
Assuming an annual salary of $30,000 per year for both resident and comparable non-resident inspectors, the net costs associated with the trial resident inspection program are cancelled by the observed increase in inspection program accomplishments.
Within the accuracy of the assumptions and geographic regional cost differences, resident inspection caused no budget impact additional to non-resident inspection.
4.7 Qualitative Judgments
.
As part of the overall evaluation process, qualitative judgments on the part of the two inspectors involved in the trial program were
' expressed as indicated below:
[
- 28 -
1917 208 i
-
.
-.
-.
.-
-
-
.- -.
.
.
!
-
.
.
i l
-
I a.
Maintenance of Inspector Objectivity:
Though difficult to assess from the inspectors' viewpoint, it was their mutual
'
i judgment that location in the proximity of the facilities I
does not reduce the objectivity of the inspector if he is aware of the problem and is constantly attentive to potential
,
conflicts in this area.
Review by the RIP evaluation team,
'
and regional supervision assessment, indicated that there
,
was no indication of loss of inspector objectivity for either
,
inspector.
b.
Licensee Cocoeration: The inspectors' assessment of the relation-ship with the licensee was that these relationships were sig-nificantly improved by the frequency of the inspection visits.
Additional information is provided in Section 5.
j c.
Knowledge of Facility Operations and Management Policies:
A benefit from the more frequent visits to the site was the
.
resultant increase in knowledge of the facility, its operations, and its management team and policies.
This apparent increase in knowledge level was obvious to the evaluation team and resulted, based upon the inspectors' analysis, in an increased capability for completion of the inspection program and in a better under-standing of the areas inspected.
This aspect alone probably accounts for a majority of the benefit identified in Section 4.1.
d.
Impac't on Licensee Performance:
The more constant attention of the inspectors to the plant problems resulted in a significant improvement in all licensees' attentiveness to regulatory require-ments.
ihis may be related to the " cop on the beat" approach to law enforcement, in that the visibility and constant association with the operating personnel resulted in greater and more constant attention being paid to regulatory requirements.
-
e.
Impact on Public Relations in Area of the Plant:
An initially surprising result of this program was the very low level of
-
public reaction to the stationing of a resident inspector.
Essentially, no media or public contact resulted from location of the inspector near :ne facilities during the first year.
During the interval when the RIP-2 field office was located in a highly visible location in a shopping center, several
" drop-in" visits occurred, and in one case a potential land buyer inquired as to the environmental effects near the D. C.
Cook plant.
After the office was moved to its current location in Benton Harbor Federal Building (a former inner city post
'
office), these contacts ceased.
During the second year there were several local citizen contacts and contacts by the press
,
related to plant events.
This upturn in local interest may
,
!
-
j..
.
i
-
9-19'17 209
_
i
..
.
.
be unique; however, it is the opinion of the inspectors and the evaluation team that continuation of the inspector's presence within easy local media access could offer a long range benefit.
No conclusion regarding the local public impact can logically be drawn from results observed during this trial program except that there has not been a strong reaction by the public to the stationing of inspectors near the site.
.
4.8 Impact on Inspectors l
The participation in the resident inspection program was evaluated in terms of impact professionally, personally, and financially.
Specific benefits and disadvantages are tabulated under the three areas.
,
a.
Professional Impact
!
1.
Benefits
[
(a)
Excellent learning opportunity.
Increased on-site
-
inspection time with emphasis on observation of operations facilitate greater knowledge of assigned facility.
(b)
Increased degree of independence.
Reduced direct supervision provided opportunity for increased initiative by the inspectors and increased authority and responsibility.
(c) Greater efficiencv d;- to fewer. distractions and interruptions.
in.....provement in efficiency was shown by increased inspection time.
(d) Greater job satisfaction. The inspectors stated that the greater degree of independence and improved
,
continuity resulted in greater job satisfaction.
-
.
.
(e)
Improved continuity in inspection activities. The inspector conducted approximately one half of all inspections at the assigned facilities which was
,
i an increase. of approximately 25% compared to the non-resident progran.
2.
Disadvan?.ajes, (a)
Recuced participation in regional training.
The
'
resident inspecto s were unable to attend formal end informt.1 training sessions which averaged once i
-
,,,
_m. j 1917 210
-"-
.-
. -.
_.
.
._
.
.
,
'
';
i
per week.
Monthly trips to the region were generally
.
scheduled to coincide with a training opportunity.
,
l (b) Reduced opportunity to exchange views with other inspectors.
This was rated as one of the strongest disadvantages by both resident inspectors.
Al though
!
frequent telephone discussions were held they are i
not considered to be equivalent to direct discussions.
(c) Unavailable for promotion during tour of duty.
This t
was necessary for the trial program and it is anticipated that a similar arrangement would be required for a routine
'
application of the Resident Program.
(d)
Difficulty remaining current with Commission and industry developments.
This was a direct result of reduced
,
direct contact with regional personnel and inability
I, to attend regional training.
b.
Personal Impact 1.
Benefits (a) Less time away from home on travel.
The resident inspectors spent only 12 nights away from home per year compared with an estimated 40 or more for inspectors working out of the Regional Office.
(b) Outdoor recreational activities more convenient due to rural location.
Accessibility to hunting and.
fishing facilities constituted this advantage.
(c)
Small town atmosphere more friendly.
This was a marginal benefit in view of restrictions on social contacts deemed necessary to avoid possible conflict
-
of interest.
2.
Disadvantages (a) Family dissatisfaction with frequent moves.
Frequent moves disrupted schooling of children, circle of acquaintances and friendships for family.
(b) Reduced availability of convenient metropolitan shopping and entertainment.
The inspectors found that especially true for major applicances and pro-cessed foods.
.
.
.
.
-3 1917 21)
-
t.
_.
!
_.. _ _ _ _. _ _
_ _. _. _
_ _ _ _.. _ _ _
.._ _.._ ___ _
......
'
l
'
.
.
.
.
.
(c)
Restriction on social contacts due to potential con-flict of interest.
In a small community, the necessary restriction of social activities with licensee personnel l
restricted the circle of friendship which may have other-a wise developed.
{
c.
Financial Impact
'
1.
Benefits
,
'
~(a)
Reimbursed moving and sale of home expenses averaged
$5300 each move (Section 4.6).
(b) Certain aspects of cost of living lower in rural area.
~
Specifically, housing and fresh locally grown produce were generally lower priced.
Housing was estimated to be 10% to 20% less expensive than in the Chicago area.
-
(c)
Reduced travel or commuting cost.
A reduction here was dependent upon location of the resident inspector's office.
One inspector had an increase in commuting cost, the other a decrease.
2.
Disadvantages (a) Household goods moving expenses not felly reimbursed.
Both inspectors had household goods in excess of 11,000 lb. limit resulting in unreimbursed expenses of approximately $360 per move.
(b)
Cost of new home loan not paid such as mortgage points and service fees.
Non reimbursed new home expenses ranged from $400 to $700 per move.
,
'
(c)
Capital gains tax on sale of home (state and federal).
This expense occurred in moving one way from a higher to a lower housing cost area since the inspectors believed purchase of a more expensive home in the
,
lower cost area would tend to make the house more i
difficult to resell. The capital gains taxes were expected to amount to $2000.
,
(d)
Delays in receipt of reimbursement of moving expenses.
Reimbursement for house sale related expenses amounting to approximately $4000 required four months, representing a loss of approximately $100 of interest.-
1917.Zi2
~
_
-
- 32 -
yw<
__
-. ___ __. ~.
_ -.. _ _. _ _ _ _ _ _ _ _...,. _
_
..
.
.
It should be noted that the specified disadvantages are not unique to the resident program but are experienced with
,
most relocations.
The disadvantages would be amplified due to the more frequent relocations associated with a resident inspection program.
-
e t
,
e e
%
W
.
19~17 213
'
- 33 -
l
- c-
,
~...~.,-
..... _ - _..
..
-... - -
.
.
.
.
.
.
5.
LICENSEE REACTION As part of the evaluation effort, the evaluation team met with each plant superintendent for the RIP facilities and discussed the program and its benefits and costs from their standpoint.
In all four cases, the plant management expressed strong support for the resident concept since it has resulted in a reduced impact upon their operating staff.
This reduction in licensee time requirements has resulted from increased mutual respect and professionalism of the inspector and licensee per-sonnel, more knowledge of the facility and its records by the inspector, Two of the and increased trust in the inspector by licensee management.
licensees did voice concern that an expected reduction in the overall support inspection effort had not been realized.
All four licensees indicated that the frequency of visits to the site
appeared adequate to maintain cognizance of the facility operating In addition, they stated that the inspector frequently called i
status.
i the site to ascertain plant status and problems on days when be was not planning to be on-site. The RIP-1 facility management indicated their
-
support for the immediate followup activities of the inspector as related to reportable event situations such that data retrieval and licensee manpower requirements were minimized.
Three of the four facility managers indicated their confidence in the inspector and their desire to maintain him continually aware of plant problems, thereby facilitating incorporation of any unanticipated regulatory requirements into their evaluations and plans.
The fourth had not developed a strong positicn in this regard, but was not negative. The inspector's familiar-ity with the record system and increased licensee trust made it possible for the inspector to obtain data and records without ;:lant staff support.
In one case, a plant superintendent indicated that the objectivity and independence of the inspector, rcther than being reduced, may actually have been enhanced by his greater iant familiarity, since he did not r
depend as greatly upon the spoken stctements of plant staff, but rather could more directly assess conditions independently following reportable This observation, taken in conjunction with regional super-a events.
vision's increased confidence in inspector-supplied information, tends
'
to offset concerns about potential loss of objectivity due to over-One licensee familiarity of the inspector with a facility and its staff.
representative noted that any apparent loss of objectivity by an inspector i
could not be tolerated by the licensee due to the potential #cr publicity adverse to the utility.
He indicated his opinion that a respcasible
licensee would request reassignment of an inspector, if the inspector's independent viewpoint were ccmpromised.
Initial concern by all four plant superintendents relative to the greater intensity of inspection effort was totally allayed by the experience
- 34 -
+. w
..
.
-.. _ -
.. -..
.. -
-
-
.-
,
..
,
.
- ,
,
i during the two years of plant operation under the RIP concept.
None of the plant superintendents identified any deleterious aspects of the RIP from their viewpoint.
All did, however, voice the strong opinion that careful selection of inspectors would be required to assure maturity, inspection experience, and operating experience, i
since greater reliance is placed upon the independent judgment of this
,
j inspector. This observation was iterated by regional supervision.
'
'
.
.
A it
.
-
,
t
I l
-
.
-
I i
.
-
.
.
1917 215
- as -
"
._-
-.-..
.. -
-
-. _... _. _ _. _. _ -..
.. - -
._ -
.
,
l.-
.
i l
'
-
j 6.
RELATED EXPERIENCE
,
!
As outlined in the evaluation program,2 it was desired to compare the j
Canadian inspection processes with the U. S. inspection process.
This i
comparison was accomplished by a visit documented in Reference 5, which relates the observations of a portion of the evaluation team following
,
their visit to the Atomic Energy Control Board of Canada (AECB). The Canadian inspection program is headquartered in Ottawa, Ontario, and at the time of the meeting had four resident inspectors stationed at two stations.
Observations of the evaluation team members concerning
,
the experience of the Canadians were consistent with the observations from the trial program.
i
,
.
.
%
.
36 -
-
.
\\9\\7 2\\6
'
. -..
.. _
-
.
.
.
..
.
.
.
.
a
'
.
7.
SUMMARY Afl0 CONCLUSI0!1S The trial resident inspection program was conducted as described in Section 3 during the two-year period ending July 1,1976, at RIP-1, and October 1,1976, at RIP-2.
Summarized below are the benefits and costs of application of the resident concept as an alternative to the regional con;ept.
Inherent within these observations, resultant con-clusions and recommendations is the assumption that Regional Offices would continue to exist, and that specialist support from the Regional Offices would be available to supplement the inspection activities of the resident inspector.
Identified benefits and costs reflect not only the quantitative measurements of variables monitored during the trial
.
program, but also include observations and conclusions of the evaluation
,
'
team developed through observations, interviews, and supervisory judgment.
7.1 Benefits
'
'
a.
Inspector Utilization:
Evaluation of relative inspection effort as measured by inspection module accomplishment has shown that the resident inspector performed 25% more inspection modules than other equivalent Region III inspectors.
(Section 4.1)
i b.
Increased On-Site Inspection Time:
Evaluation of records indicates that both resident inspectors were on-site at least
,
50% more than equivalent inspectors both in Region III and in the balance of the regions.
In addition to the increased total i
site time, more frequent visits have permitted better time utilization by the inspector and a more frequent assessment of
'
plant status.
(Section 4.2)
c.
Increased NRC Awareness:
Discussions between the evaluation team i
and the regional supervision revealed that the resident inspectorc'
presence enhanced NRC knowledge of plant status and problems, and
,
j permitted a reduced threshold for inspector response to plant problems.
Followup and resolution of identified problems were also enhanced by the proximity of the inspector.
Office of Inspec-tion and Enforcement (IE) supervisory judgments in this area were
.
l reinforced by similar observations by facility management.
(Sections 4.4 and 5)
d.
ImprovefInspectorknowledae:
Inspector knowledge of the plants being inspected, including their operating systems and character-istics, their management, the management systems, and the records
'
systems was determined to be significantly improved over typical non-resident inspectors based on observations by the evaluation team members.
(Section4.7)
.
- 37 -
.
1917 217 i
)
~
.
.
.
,
~.
e.
Inspector Acceptance by Licensee:
Licensee acceptance of the presence of the inspector was observed to have been significantly enhanced by the development of confidence, mutual respect, and rapport between the licensee and the inspectors.
This resulted in easier access to facility records and more independence of inspection effort.
(Section 5)
.
f.
Licensee Time:
Facility management stated that a reduction in plant staff support required to support the IE inspector during conduct of inspections was a direct result of the increased knowledge of the resident inspector regarding the facility and its administrative practices.
(Section 5)
g.
Management Control:
Both resident inspectors observed that due to the more constant association with the plant staff, greater emphasis was generally provided to regulatory requirements as expressed in administrative procedures and controls for plant
!'
operation.
It was noted that the compliance history had not I
reflected the change.
(Section 4.7)
h.
Surveillance:
Increased direct observation by the resident inspector was facilitated by greater time availability and access to the plant as indicated by inspector interview and by review of trial program records.
(Section 4.2)
1.
In-Office Inspection: As a result of being located closer to the facility site, the capability to borrow plant records for inde-pendent and more effective review within the RIP office was enhanced.
This capability was primarily utilized by the RIP-1 inspector, but not by the RIP-2 inspector.
This added flexibility is not necessarily a benefit since it tends to reduce the visi-bility of the inspector, even though it may increase his work capability; however, if properly balanced with on-site time, greater work output could result.
Therefore, this flexibility is identified as a benefit for the purpose of this report.
(Section 4.2)
j.
Inspector Convenience: As a result of location of the duty station near the facilities being inspected, travel time away from home and family was significantly reduced.
The inspector's l
time-in-travel status away from his family was less than 10% as compared with 25-30% for typical inspectors.
(Section 4.8)
,
!
k.
public Reaction:
Though initial public response to stationing of the resident inspectors was minimal, recent experience at both RIP-1 and RIP-2 have indicated some degree of media and public awareness of the resident inspectors.
Both inspectors have been
,
I involved in media reports concerning their assigned facilities.
(Section 4.7)
- 38 -
f
._.-
--
- _. - _. _. - -.. - - -
_...
- _. _ _.. -
..
.
.
.
.
.
'
7.2 Costs a.
Monetary Costs:
The NRC non-salary expenditures for the RIP trial program were approximately $8,000 per RIP site per year.
,
Added expenditures were primarily a result of increased adminis-
'
{
trative costs and costs associated with inspector relocation.
Adjustement to these expenses for increased site time attained i
and higher productivity in inspection program accomplishment i
reduced the cost differential to insignificance, less than
-
$150 per RIP site per year.
(Section4.6)
b.
Monetary Cost to Inspector: Costs incurred by the inspectors which were not reimbursable under current travel regulations (relocation reimbursement) and income tax laws resulted in unreimbursed costs of approximately $3,000 each over a two-year period. This represents approximately 5% of salary.
(Section 4.8)
t l
c.
Training:
Both formal and informal training of the inspectors by the Region have suffered because of their remote locations.
This cost was partially offset by improved inspector knowledge of his assigned facilities.
The inspectors visited the Regional Office approximately once per month, coordinating these meetings with planned training programs; however, informal exchange with other inspectors and with supervision did not occur on the
,
frequency that would prevail if the inspectors were based in the Regional Office.
(Section 4.8)
d.
Communications:
Regional Office communications with the inspectors were reduced as a result of the remote locations.
Nonetheless, the communications from the inspectors to the Region were more timely and knowledgeable, thereby partially offsetting this potential cost.
(Section 4.3)
__.-
__
7.3 Conclusions _
'
Based upcn the results of the evaluation, the following conclusions have been reached by the evaluation team:
a.
The concept of resident inspection applied to this trial program is viable and preferred for certain reactor safety-type inspections, and feasible for application under the direction of regional m3nage-ment, b.
Applicction of the concept apr.eers to be restricted by the limitco availability of suitably quclified inspectors, and candidate locations.
)9)7 219
-
- 39 -
g
,
W.w m --.
--e..
-..
. --
-
..-..
.----
n--
.,
- - -.
.-
-
.
.-.
.
'.
c.
An improvement in inspector utilization has been quantitatively measured.
In applications where this increase could be effec-tively utilized, increased monetary costs could be precluded.
d.
An improvement in licensee compliance' attitudes has been cuali-tatively observed at all but one licensee. At that licensee,'an improvement in defintion by IE of the causes of noncompliance has resulted in enforcement meetings with the licensee.
No change in noncompliance frequency was observed at any of the RIP facilities which could be attributed to the RIP.
e.
All participating power plant managers observed that a resident inspector concept appeared to be an effective method for NRC implementation of its inspection responsibilities.
They preferred the resident concept over the normal mode of periodic inspections; however, all emphasized the importance of careful selection of
-
I suitably qualified inspectors.
I f.
No tangible evidence or other indication of loss of inspector objectivity was identified during the trial program.
.
g.
Additional expenditures due to the trial program were offset by increased productivity of the resident inspectors.
h.
Significant monetary costs to the inspectors were nonreimbursable within existing regulations pertaining to relocation.
These costs, coupled with the expected reluctance of employees to relocate to and from resident locations on a three-year interval, could restrict the availability of otherwise qualified personnel.
.
i.
Because of the more constant interface with the licensee personnel, the gre6Lcr reliance placed on the inspector's judgment, his remote location, and increased requirements on inspector integrity, the
"
inspectors must be very carefully chosen to assure their maturity, p
experience, integrity, and dedication.
The greater demands en
"
resident inspectors relative to nonresident inspectors were considered
'
l to be compensated for by professional and personal benefits realized by the resident inspectors.
j.
Qualitatively, significantly higher knowledge levels of-the inspectors concerning the facilities, their management, and the administrative practices were attributed to the t esident inspector environment.
'
i I
1917 220
!
-
i
!
- 40 -
.
'
1f W
I
..
.
.
.
.
8.
RECOMMENDATIONS Based on the conclusions and observations of the evaluation team, the
,
following recommendations are proffered.
These have been categorized as direct, i.e., recommendations specific to the objectives of the trial program, and related, i.e., recommendations developed as a side benefit of conducting this trial program.
I
-
t 8.1 Direct Recommendations a.
Predicated upon the availability of suitably qualified and experienced inspectors, the resident inspection concept is
,
recommended as a means of inspection in the following specific applications in which the benefit to the NRC should be signi-ficant:
g f
-- A cluster of three or more operating reactor units within a radius of approximately 25 miles.
.
',
-- A single or multi-unit facility during the preop /startup phase (one year before licensing to one year after license
!
issuance).
i
-- A single or multi-unit operating facility which is considered by IE to be a poor performer with regard to compliance with regulatory requirements or one whose management is considered to be recalcitrant.
i b.
The inspection program currently being conducted at power reactor facilities should form the basis for resident inspection.
Minor modifications to current inspection requirements should be initiated in order to maximize the potential benefits of resident inspection.
Examples include greater freedon for random observation, defined re-
!
quirements for "backshift" inspections, increased sample sizes for specified inspections, and more specific guidance for inspection of corrective actions taken by the licensee following reportable events.
Additionally, the scope of activity should be broadened to include certain inspection activities currently performed by specialist in:;pecto c.
Criteria and proceiures for program audit and resident insoector evaluation shculd be develcped contingent upon future implementation of resident inspection.
d.
Resident inspecter tours should be for pre-established and finite tines, probably not to ex eed three years.
c.
Because of the remote locations, care must be exercised in the selection of resident inspectors to assura their' experience, maturity, and dedicatior..
.
-i
- 41 -
1917 221
.-
.s
.
.
f.
Professional development and areer planning should be conducted for IE personnel and should incorporate the resident inspector.
Consideration should be given to developing specific commitments, assurances, or preference for post-resident inspector assignments regarding location and position.
g.
A:rangements which would provioe total compensation of all moving and real estate costs related to resident inspection assignments should be considered as alternatives to current practices.
This is one aspect of incentives that may be necessary for otherwise qualified inspectors. Arrangements similar to some industry practices may appear reasonable.
8.2 Related Reconmendations I
a.
Region III staff should develop and publish a procedure based on
{
their experience for establishment, support, and closecut of
'
resident offices, b.
The RIP environment, including expert resident inspector knowledge of plant and licensee, provides fertile opportunity for training of new inspectors.
This opportunity exists particu-larly durina test and startup phases during which time orientation could be very rapid.
This is seen as a complement to existing technical training programs within IE, rather than as a substitute.
c.
Rev'.w of conclusions drawn from t!'is trial program reveals that the concept's viability is not dependent upon the status of the ft:111ty being inspected, i.e., the concept appears equally f.asible for application during the construction, test and startup, aral operating phases.
The following variations of the trial program are recommended:
.
-
-- A limited program for resident inspection of facilities under construction should be initiated in more than one NRC Region.
As with resident inspection of operating reactor facilities, this would facilitata increased direct observation of activitie.s in progress, increased inspector visibility and availability to craft workers, which are deemed important byproducts of resident inspection. The logistics, management and administrative practices, which evolveo from the trial program at operating
facilities, should be directly applicable.
-- Clusters or combinations o.' units described in Section 8.1 aoove
'
could warrant application of two or more resident inspectors which would facilitate training of a lesser experienced insi;ector by a more. experienced inspecto:. The Canadian experience indicates this type of inspe: tion program5 reduces certain drawbacks of the resident program througl. assignment of more than one inspector to one office.
!
"
. -u.
1917 222
_.
.
.*
..
'..
.
9.
REFERENCES
Memo from B. H. Grier to J. G. Davis (Subject:
Resident Inspection Program), dated 3/19/74, with attachments.
" Trial Resident Inspection Program Report of Interim Benefit-Cost Evaluation," R. E. Hall and E. L. Jordan, dated 2/76.
.
Memo from B. H. Grier to J. G. Davis, et al (Subject:
Resident Inspection Program), dated 8/1/75.
Memo from J. H. Sniezek to B. H. Grier (Subject:
Benefit-Cost i
Analysis for Pilot Resident Inspection Program), dated 7/27/76.
i s
Memo from R. E. Hall and E. L. Jordan to G. Fiorelli and J. H. Sniezek (Subject: Trip Report - Canadian Resident Inspection Program), dated 10/7/75.
Letter from E. W. James, Wisconsin Public Service Company, to J. G. Keppler, Director, NRC Region III, dated 7/16/76, comment-ing on Resident Inspection Program at Kewaunee.
.
.
%
.
43 -
'
-
,
1917 223
,
EftCLOSURE 2 i,,-,
l i
CAfiDIDATE SITES - AS OF OCTOBER 1977
,
1.
Cluster of three or more operating reactor units within a radius
'
of approximately 25 miles:
Browns Ferry 1, 2, 3 Dresden 1, 2, 3 Indian Point 1, 2, 3 Oconee 1, 2, 3 Point Beach 1 and 2/Kewaunee D. C. Cook 1 and 2/ Palisades 2.
Reactor units entering preoperational test and startup sequence:
I Zimmer 1
l'
Hatch 2 Sequoyah 2 Summer 1 La Salle 1 Shoreham Salem 2 McGuire 2 Watts Bar 1 Farley 2 Grand Gulf 1 3.
Candidate reactor units under construction:
'
Bellefonte 1 and 2 Braidwood 1 and 2
'
Byron 1 and 2
,
~
Callaway 1 and 2
'
Catawba 1 and 2
'
Cherokee 1 and 2
Clinton 1 and 2
'
-1-ENCLOSURE 2
.
"i 1917 224
-. _ -
. - -.. -.
_. _..
-
..
-
- -.
-
-
.
'
,
.
g;
.
~.
'
Comanche Peak 1 and 2 Grand Gulf 1 and 2
Hartsville 1, 2, 3, 4
-
l Hope Creek 1 and 2 La Salle 1 and 2
-
Limerick 1 and 2 Midland 1 and 2 North Anna 2, 3, 4 Palo Verde 1, 2, 3 Perry 1 and 2
,
San Onofre 2 and 3
,
Seabrook 1 and 2 South Texas 1 and 2 Susquehanna 1 and 2 Watts Bar 1 and 2 WPPSS 1, 2, 4
.
e
%
\\9\\1 225
.
e 2-g
-
,
. _ _ _.. _ _ _
___.__ _ _ _. _ __
-
.
. -
.
$ t..
'
October 25, 1978 SECY-78-554
'
UNITED STATES NUCLEAR REGULATORY COMMISSION OM UNiMDN-iINA-('.ONSEMT C/Uf#Dn2 ITfM For:
The Commissioners
.
From:
John G. Davis, Acting Director Office of Inspection and Enforcement Thru:
Executive Director for Operations L.d
-
Subject:
LICENSEE REGULATORY PERFORMANCE EVALUATION
Purpose:
The purpose of this paper is to inform the Commission regarding the status of efforts by the Office of Inspec-tion and Enforcement in licensee regulatory performance evaluation and to obtain Commission approval of a two year trial orogram.
Discussion:
IE has been working to develop techrtiques for evaluating the regulatory performance of NRC licensees for several
years, with intensified effort over the last two years.
" Regulatory performance," is meant to convey the ability of the licensee to meet regulatory requirements and to avoid reportable events inat appear to be directly under the control of the licensce.
" Regulatory performance" does not involve reliability, availability, earnings, or other measures which may be used to measure performance.
Licensee Regulatory Performance Evaluation (LRPE) is the effort to evaluate the regulatory performance of licensees on a national basis.
It has as its objectives:
.
Identification of factors that lead to different levels of regulatory performance.
Effective and efficient use of NRC inspection resources.
.
Infomation from the evaluation process also can be used to evaluate aspects of the NRC inspection program.
D g') '
.
H. D. Thornburg, RCI i917 226 O
,/ r'
Contact:
4, g
49-28484
_
e 78tto766a2
!
'
'~
-2-The basic method of LRPE is to identify licensees whose regulatory perfonnance is most different from the majority of licensees in the same class.
These "different" licensees are examined on a case-by-case basis to identify the characteristics that lead to the differences.
Actions then can be taken, if needed, to upgrade licensee regulatory perfonnance. The thrust of LRPE is an upgrading, as appmpriate, of performance.
The enclosed paper, entitled " Licensee Regulatory Performance Evaluation," defines the concept of licensee regulatory performance, describes why IE wants to evaluate l
it, and suggests the uses that may be made of the results.
l The paper also describes the evaluation approaches that IE has considered and offers some ideas how IE may develop and use an " integrated methodology" that incor-porates selected aspects of each of the three methods considered to date.
Finally, the paper provides a sumnary of value-impact considerations and plans and schedules for future actions.
Defining and agreeing upon the reasons for LRPE and
suitabic metSods for its conduct have been difficult.
Concepts and positiont have been modified as new insights are developed.
Staff agreement still has not been achieved. The results of efforts in LRPE have not been made public. fio public nor industry comments have been requested.
IE management believes that the potential benefits--resource management and performance upgrading--
are sufficient to move forward into a trial program of LRPE.
IE proposes to implement a trial program for evaluating the operating reactor licensees on the basis of 1978 and 1979 data.
As the program proceeds. IE will monitor its results to identify changes which may be needed. An interoffice steering group will be appointed for the trial program in December 1978. The trial is scheduled for completion in December 1980.
By March 1981, IE will evaluate the trial and report to the Commission with reconnendations for adopting LRPE as an ongoing program-matic effort, modifying the trial program, or abandoning this approach to evaluation.
e m7 n7
-
.-,..
-3-The documents upon which this staff paper is based (these are listed in Attachment 1 to the enclosed paper) have been treated as predecisional information.
Upon Commis-sion approval of the trial program, IE recommends that these documents be released to the Public Document Room.
The necessary logistics probably will take about 10 days.
Coordination: The Office of Management and Program Analysis and Standards Development concur.
The Office of Nuclear Material Safety and Safeguards has no objection to the proposed program.
NRR concurs with the intended objectives of the trial program.
However, because the mechanism by which these objectives are to be achieved has not yet been developed, NRR cannot offer a view as to the overall acceptability.
Accordingly, NRR recommends that the overall program be subjected to periodic program office review.
The Executive Legal Director has no legal objections.
-
/
O
- ~., '
-J
.-
,
- ,
J.ohn G. Davis Acting Director Office of Inspection and Enforcement
-
Enclosure:
" Licensee Regulatory Performance Evaluation Paper" This paper is scheduled for consideration at an Open Meeting during the Week of October 23, 1978.
Please refer to the appropriate Weekly Commission Schedule, when published, for a specific date and time.
DISTRIBUTION Commis:ioners Commission Staff Offices Exec Dir for Operations Regional Offices Secretariat w
w.1 1917 228
-
.
'
O LICENSEE REGULATORY PERFORMANCE EVALUATION A REVIEW 0F PAST EFFORTS, STATUS, AND FUTURE PLANS Introduction By the term " licensee regulatory performance" the Office of Inspection and Enforcement (IE) means the ability of a licensee to meet regulatory requirements and to avoid events whose occurrence appear to be directly controllable by the licensee.
This does not include availability, reliability, earnings, or othe.r measures sometimes used to evaluate the performance of utilities.
The Office of Inspection and Enforr.ement (IE) has been working to develop techniques for evaluating the regulatory performance on a nationwide
.
basis since early 1976.1 Studies of various techniques have revealed
'
draw backs that have precluded adoption of any one technique.
Yet, IE management believes that the ability to distinguish between various levels of licensee regulatory performance will give NRC a better basis for managing IE's inspection resources, by focusing inspection effort where it is most needed, and for identifying licensees whose performance should be examined.
IE believes that a trial program should be initiated to further develop an acceptable technique and to test the technique.
This paper defines the concept of licensee regulatory performance,
describes why IE wants to evaluate it, and suggests a number of uses that may be made of licensee regulatory perfomance evaluation (LRPE)
resul ts.
The paper also describes the LRPE approaches that have already been considered by IE and offers some ideas of how IE may develop and use an " integrated methodology" that includes, but may not be limited to, selected aspects of each of the three methods considered to date.
Finally, the paper provides a summary of the costs and benefits of LRPE and a schedule for completion of identified mile, tones.
A review of the regulatory practices of other agencies has been conducted by Teknekron, Inc. under contract to IE.
An initial survey of inspection and enforcement programs of twenty agencies revealed the following:
- 16 identified some kinds of criteria that could be used to assess their own effectiveness
- 7 have an assessment process that was a clearly defined element of program policy.
- 4 compare regulated facilities in tems of perfomance
- 7 use ratings in absolute tems.
Ref: NUREG/CR-0051 Vol. 1.
_
. -.
-2-Purpose and Objectives Licensee Regulatory Performance Evaluation (LRPE) is an attempt to systemize, on a formal basis, a method of evaluating the performance of licensees, in a regulatory sense, on a nationwide basis.
The objectives of LRPE are:
Identification of factors that lead to different levels of
.
regulatory performance Effective and efficient use of NRC inspection measures
.
Information from the evaluation process also can be used to evaluate aspects of tne NRC inspection program, I
i
'
Conceptually, the results of LRPE could be general groupings of licensees according to their performance.
Most probably there will be three perfomance (2) a "majoritgroupings (1) a " majority grouping"of licensees t majority grouping and (3) y +" grouping that performs better than the as well as the majority grouping.a " majority
" grouping that does not perform If LRPE is successful, it would enable IE to identify on a national basis:
1.
A group of licensees that appear not to perform as well as most others.
These licensees then could be examined to determine:
Whether, in fact, their performance is not as good as others.
.
Whether the level of performance is general within that plant's
.
operations or specific to certain areas of the plant operations.
Causes for the level of perfomance.
.
Corrective actions to improve performance.
.
-
2.
A group of licensees that appear to perform better than others.
These licensees then could be examined to detemine:
Whether, in fact, their perfomance is better.
.
If it is better, what are the factors that influence or cause
.
the performance.
O 1917 230 c
.
-3-O If the technique proves successful, LRPE could be used in several ways:
1.
Managing of IE resources by directing various levels of inspection attention according to groupings.
2.
Identifying the characteristics of the " majority +" performing licensees so that the industry could have access to these charac-teristics (if not proprietary) for improvement.
3.
Identifying causes of " majority " performance and focusing on causes so that improvement could be realized.
4.
Informing the public and licensees, in a summary fashion, on a periodic basis of the licensees' regulatory performance.
5.
Serving as a basis for periodic meetings between NRC regional management and licensee management for discussions of licensee performance.
In addition, LRPE will give IE management the ability to manage this
"further examination" rather than rely to a high degree on regional judgments which by their very nature lack a national perspective.
Background Over the years, a form of licensee regulatory performance evaluation has been done on a individual licensee basis.
The manner in which a plant has perfomed against regulatory requirements has been reviewed, on a case-by-case basis, as a part of the routine inspection effort.
Differences in inspection attention given by IE to licensees has been determined largely by the " problems" the licensee encounters and usually has been done on a regional rather than national basis. There has been no fomal program for considering licensee performance on a national basis, and little program for reacting to licensee perfomance othcr than specific reaction to identified areas when IE believes improvement is needed.
In trying to systemize a method to evaluate the regulatory performance of NRC licensees, IE has undertaken three separate efforts, each involving a distinct approach. The first, which can be described as the " Statistical Method," produces single-valued dimensionless ratings (or Z-scores) for each licensee in a given class (in this case, operating reactors) that reflect relative numbers and types of noncompliances.
The numbers of those Licensee Event Reports (LERs) attributable to personnel and procedural errors and the extent of personnel exposures and effluent releases attributed to each individual licensee are also considered, rh 1917 231
+%
.
.
,
-
-4-O The second approach, which can be characterized as a " Trend.^nalysis Method," involves detailed examination of licensee events, identification of those events that are repetitive or " causally-linked," and an evalua-tion of the responsiveness of each licensee's management in reacting to such events.
The third approach, the " Regional Survey Method," is more subjective, it involves a compilation of the qualitative judgments of regional managers and inspectors on a number of factors associated with the safety and security of licensed facilities. Work on these three approaches has been accomplished both in-house and under contract and reports developed.Z More detailed descriptions of each of these methods are provided below. Although the basic data used for the " Statistical l
Method" and " Trend Analysis Method" are available in publicly available l
records, the reports themselves have previously been treated as " pre-decisional" infomation.
Licensee Regulatory Performance Considerations Experience, thus far, shows us that the data and other influences make performance evaluation and the attendant assignment of licensees to any groupings imprecise. The concept of performance, like the concept of
safety itself, is elusive.
Consequently, any grouping, particularly at this stage of development of LRPE, should be considered, at best, a
" director of attention," pointing IE's attention at a group of licensees worthy of more specific examination.
A hazard of proceeding into LRPE is that the groupings would be considered to sharply distinguish between the safety of operations of plants. Our efforts thus far do not support this. The fact that a licensee appears in the " majority " grouping does not mean in a quantifiable sense that the licensee is less safe than licensees in the " majority" and " majority +"
groupings. The groupings give IE management the ability, on a national level, to identify licensees for further examination aiming at improvement if necessary.
Each plant is subjected, on a plant-by-plant basis, to a formally described and conducted inspection program and continuing review by the Office of Nuclear Reactor Regulation. The plant is evaluated, on a continuing basis, as to its ability to operate with regard to safety.
The NRC is charged with the protection of the public. Hence, the continuation of authority to operate a plant attests to the judgment of the NRC that the plant is operating with adequate safety.
LRPE does not change that judgment.
2A list of License Performance Evaluation reports is provided in
Attachment 1.
nl 1917-232'
.
~
.
-5-O The tendency in an approach such as LRPE is to focus on the " majority "
group. However, IE has a strong interest in the " majority +" group.
IE intends also to examine those licensees on an individual basis to deter-
~'
mine whether their grouping is appropriate.
If so, IE hopes to identify the characteristics, within these operations, which contribuh to these
" majority +" regulatory performances.
If these factors can be identified they should be publicized (unless proprietary) for the benefit of the industry.
A second hazard of LRPE is that it could -- because it involves compara-tive grouping rather than absolute assessments -- become a constant
"ratcheting" technique.
Comparatively, some group of licensees could always appear " majority ". As experience is gained in LRPE, an attenpt
,
will be made to identify a " threshold" above which no special actions would be taken by IE. The goal of LRPE and the IE actions would be to I
achieve an industry-wide condition where all licensees remain above such a threshold.
Summary of Licensee Performance Evaluation Methods The Statistical Method is a technique developed in-house that was applied to the evaluation of operating reactor licensees. The analysis is based upon four measures of performance: numbers of noncompliance findings,
numbers of licensee-controllable events, amount of effluent releases, and amounts of personnel exposures.
For each of these measures, each licensee's performance is described relative to that of the other licensees in the same class. This relative performance is then converted to dimensionless ratings, or Z-Scores, for each licensee.
An overall rating (Z-Score) is obtained by computing a subjectively weighted sum of ratings for each of the fotr factors.
The methodology accommodates different severity levels of noncompliance and adjusts noncompliance ratings to accm.t 'or differences in the amount of NRC inspection time required to identity the noncompliance in each case.
The Statistical Method resulted in each licensee receiving a numerical score.
Licensees could be given a relative ranking based on these scores. This was not the intent of this method; however, the ability to rank licenssas relative to their peer group is inherent in a statistical approach to licensee evaluation.
The assignment of a level of precision, which could lead to such a ranking is neither supported by the technique nor the data used in the calculations.
Concerns about this methodology expressed by various staff members are:
1.
One product of the evaluation, a single-valued ranking of licensees, may not be warranted by the precision of the data and is affected by the subjective weighting of factors.
O 1917 233
-
.
-6-
2.
".abers of items of noncompliance may not adequately describe the
.evel of safety or security of a licensed facility.
Variations among licensees in the significance of noncompliance will affect the quality of the Z-scores.
3.
Inspection differences between regions and individual inspectors may mask the relative performance of the various licensees or be inseparable from licensee performance.
4.
Requirements for the various licensees (i.e., technical specifica-tions) may vary significantly enough to render the number of items of noncompliance an indequate measure of performance.
)
5.
Other exogenous variables may make it difficult to isolate the impact of LRPE on licensee perfonnance, e.g.
Revised Inspection l
Program, pending increase in civil penalty authority.
Each of these concerns involves judgment and differences of " degree";
each has been considered at length by staff. Despite these differences of opinion, some aspects of the Statistical Method should be considered in any LRPE method.
First, noncompliance findings are a direct output of HRC's regulatory program; no LRPE method is complete without some consideration of noncompliance findings.
If there are some regulatory
deficiencies that detract from the meaningfulness of noncompliance findings (e.g., nonuniformity, variations in safety significance), then these regulatory weaknesses should te corrected or acknowledged as impacting LRPE accuracy.
Numbers of noncompliance findings, are believed to be reasonable indicators of licensee regulatory performance.
The Trend Analysis Method is an approach developed by Teknekron, Incor-porated under contract to IE. This method involves detailed subjective analysis of LERs for the purpose of categorizirg then, as " facility" problems reflecting reliability or similar problems bepnd the direct coatrol of the licensee, or as " personnel" or " management" problems that reflect human failure. By separating all LERs as to the reactor sub-system in which they occur and by analyzing patterns of LERs for each subsystem, Teknekron believes it is possible to identify trends of repetitive or " causally-linked" LERs that characterize a marginal performer and may allow NRC to predict the occurrence of actual incidents.
Staff concerns about this Trend Analysis Approach are that its predictive capability has not been established because Teknekron has conducted only a limited number of case studies based only on historical data, that it may be costly in terms of manpower required to conduct such analyses on a routine basis for all major NRC licensees, and that the NRC automated data base may not be complete enough to support the analysis at present.
.
~#
1917 234
.
...
-7-O The main advantage of the method is that it is based on analysis of actual safety or security related events.
Some treatment of these potentially significant events, at an appropriate level of detail, should be considered in any,LRPE approach taken in the future.
The Regional Survey Method involves the assessment (f each facility by NRC inspectors and regional management. The judgmen.s of other NRC staff members familiar with the facilities may be apropriate for future efforts.
In the only effort of this type undertaken to date, IE obtained the assistance of Hay Associates, in developing a questionnaire and conducting a survey of those employees involved in inspection of operating reactors. Each survey recipient was asked to assess the "importance to safety" of a number of potential rating factors. Then, each inspector g
and regional manager was asked to rate each of the operating reactor
-
sites he was familiar with in terms of its:
(1) overall safety (on a l
scale of " acceptable" to " exceptional"), (2) site safety in specific areas of operation, and (3) the stringency of its requirements.
Each recipient was encouraged to offer narrative coments on the safety of each site.
In many cases there was a significant variation in the rating of a given facility by individual inspectors.
Subjective judgments of selected NRC staff members are an important element in any LRPE program, because the people who work with plant
employees and facilities on a frequent basis often have insights into perfonnance that are not immediately apparent in an isolated review of noncompliance and licensee event data. Yet, the Regional Survey Method should be recognized for what it is -- collected opinions.
As any opinion survey, care must be exercised in its use. The opinions are subjective and may be affected by the make-up of the individual.
They may not be clearly supportable by fact.
Also, the judgments may be unduly influenced by the "last contact" with the licensee and the personality of licensee representatives. Even with those concerns judgments of qualified NRC employees are highly valued by NRC and IE management in making operating and program decisions; a systematic and explicit compilation of these judgments will be a valuable component of any LRPE program.
As indicated above, each of the three LRPE methods had strengths and shortcomings in the view of the IE Staff. The results of the Trend Analysis Method especially with the present limited sample cannot be compared with the results of the remaining two methods, the Statistical Method and the Regional Survey Method.
The results of the latter two methods did not agree completely.
For these reasons it was apparent that a method should be adopted that takes advantage of the strengths and compensates for the shortcomings of the methods attempted to date.
$,
m 7 235
+rn
.
,,.
-8-O Accordingly, IE believes that an Integrated Approach is needed for Licensee Regulatory Perfonnance Evaluation.
This method could incliide what IE considers the best portions of the Statistical Method, the principles nf the Trend Analysis Method, the general approach of the Regional 3.:rvey Method and other techniques to be developed.
A liceisee's regulatory performance might best be described by a combination of factual and interpretive information.
The factual component of per-fonnance could include the licensee's noncompliance history over the period, a description of significant licensee events, any escalated enforcement sanctions taken by NRC against the licensee, a description of management meetings held between NRC and licensee management, and any other information considered pertinent to the licensee's performance.
It should be noted that enforcement history would be factored into LRPE.
Future enforcement action would not be predicated on LRPE, but rather
,
would remain based upon the specifics of noncompliance at issue. The
i interpretive component of the performance evaluation could include the Region's assessment of the significance of all the factual infonnation and a general description of inspection activity planned during the next year by the Region to cause improved regulatory performance.
Included in the Region's assessment could be an assessment of the significance of the licensee's noncompliance.
During development of the Integrated Approach a foremost concern will be
whether the results provide a true measure of licensee performance.
Qualifications of the validity of results will be articulated.
These integrated analyses would be documented in a report that would be made available to licensees, the NRC staff, and the public.
The results of these analyses will be used as a basis for periodic meetings with selected licenses.
Value-Impact Considerations Licensee performance evaluations have been performed in the past by both Headquarters and Regional staffs using a variety of techniques.
By consoli.iting these fragmented efforts, IE will be able to systematically conduct these necwsary evaluations within existing resources.
An estimated 3 man year.i per year will be used to develop, conduct and evaluate the trial program.
IE does not believe that the adoptian of a systematic LRPE process will have any direct resource impacts on licensees, excluding possible costs to the licensee to upgrade his performance.
1917 236
,
..
>
-9-O IE believes that the benefits of being able to evaluate licensee regulatory performance could provide a means for improved management of inspector resources and for identifying factors to be used for upgrading of regulatory performance as appropriate.
Plans and Schedule If approved, IE intends to move promptly to develop the Integrated Approach to Licensee Regulatory Performance Evaluation.
The integrated approach will serve as a basis for the Trial Program using 1978 and 1979 data. As the Trial Program proceeds, its progress will be monitored and modifications made as appropriate.
By March 1981, a report to the Commission will present an evaluation of the Trial Program and recom-l mendations concerning LRPE.
IE will document the findings of the Trial Program in three reports --
one for the 1978 analysis of operating reactors, one for the 1979 analysis, and one assessing the LRPE Trial Program.
Each of these will be made available to the public.
Milestones associated with these plans are:
Before December 1978 Release existing LRPE reports to the PDR December 1978 Appoint interoffice steering group for Trial Program February 1979 Initial T-ial Methodology for Integrated Approach complete April 1979 First report (for 1978 data) complete April 1980 Second report (for 1979 data) complete December 1980 Assessment of Trial Program complete March 1981 Report to Commission on LRPE 1917 237
.$
_
.
_
'
u.,
,
,
Attachment 1 The Licensee Regulatory Performance Evaluation Reports prepared by and for IE and listed below:
1.
Draft Report - An Evaluation of the Nuclear Safety-Related Management Performance of NRC Operating Reactor Licensees During 1976 - February 1977, E. Morris Howard, Project Director.
2.
Update of Draft Report - September 26, 1977, E. Morris Howard to E. Volgenau.
3.
Individual Site Ratings from the IE Employee Survey on Evaluation of Licensees - April 1978,..S. K. Conver, IE Study Group.
I 4.
Licensee Performance Evaluation, Phase I Report, NUREG/CR-0110, Teknekron, Inc. - May 1978.
-
,,
ma ns
-