ML18107A512

Procedure 71151, Performance Indicator Verification.

ML18107A512
Person / Time
Site:	Salem
Issue date:	08/23/1999
From:	NEW JERSEY, STATE OF
To:
Shared Package
ML18107A507	List: ML18107A506 ML18107A509 ML18107A512
References
71151, NUDOCS 9909070059
Download: ML18107A512 (2)

Text

INSPECTION PROCEDURE COMMENT FORM lnspectigq Procedure No.: _ _........_....:....;:""------Attachment No.: _ _ _ _ _ _ __

Title:

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Inspection Report No: \ Inspection Type: Reside:UDRSffeam .

Plant Name: S'*._/eW\ \ Region: I Date(s): 1t1q/19 - i/23/qc; 8/ 2-/tjq- ~/0/ f9 Address the following statements using the following rating scale: 1= Disagree, 2= Moderately Disagree, 3= Neutral, 4= Moderately Agree, S=Agree. Please identify errors and inconsistencies in the procedure and provide comments and suggestions for imprQ_ving the procedure, *

1. The level of effort required for the inspection was consistent with that Disagre@ 3 4 5 Agree in the IP. If not, what is the appropriate level of effort and basis for IP revision?

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2. The procedure met the inspection objectives. Disagree 1@3 4 5 Agree If applicable, describe how the procedure (or how it was implemented) failed to meet t~e im~pection objectives.

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3. The inspection requirements were appropriate based on risk.

What inspection requirements should be added, deleted or revised Disagree 1. 2 3b Agree based on risk? Based on implementing the Significance Determination Process for inspection findings, how should the inspection requirements be revised to better identify. risk significant findings?

4. The inspection procedure was clear and easy to use. If not, how Disagree 1 2~gree should the inspection guid1;mce be revised to better clarify the inspection requirements?

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5. The IP does not result in an unreasonable impact on licensees. Disagree 1 2 3 4{§)Agree How should the IP be revised to preclude unreasonable licensee impact?

Figure 4.2 - Inspection Procedure Comment Form 9

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11\lSPECTION PROCEDURE 71151 COMMENTS

1. The manpower estimate of 80 man-hours per year to verify all performance indicators per site is not realistic. These verifications are performed by numerous resident and regional based inspectors. Each inspector will need to spend time 'becoming acquainted with the data collection process and personnel responsibilities in order to access the data needed to verify each PI. This is especially more time consuming in the initial verification effort, although even in the most efficient situation, 80 man hours to verify 16 PI' s could only be accomplished with an extremely small sample and no follow up investigation when a questionable data point is uncovered.

2. Sections 02.04b and c provide guidance on how an inspector handles discrepancies found through an inspection of a sample of data. If an inspector uncovers a PI discrepancy in a small sample of data, then an increased sample should be inspected. It is unacceptable for a problem to be uncovered, even if its catagorized as minor, in a small sample without further inspection.

4a. Section 02.02 states that "performance indicators ..... will be verified annually by the resident inspectors." This should be revised to state that either resident inspectors or regional based inspectors will verify performance indicators.

4b. Section 02.02, paragraph d. states that "as necessary, observe the plant activity that generates the PI data .... " The procedure should be specific with regards to what activities the inspector is expected to observe.