ML19262D165
| ML19262D165 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/1980 |
| From: | Ahearne J NRC COMMISSION (OCM) |
| To: | Hart G SENATE, ENVIRONMENT & PUBLIC WORKS |
| Shared Package | |
| ML19262D148 | List: |
| References | |
| NUDOCS 8004240200 | |
| Download: ML19262D165 (5) | |
Text
a f* **%e UNITED STATES j,
[,j NUCLEAR REGULATORY COMMISSION WAS HING TON, D.C. 20555 March 17, 1980 OFFICE OF THE CHAIRMAN The Honorable Gary Hart, Chairman Subcomittee on Nuclear Regulation Comittee on Environment and Public Works United States Senate Washington, D.C.
20510
Dear Mr. Chaiman:
In accordance with Section 236 of the Legislative Reorganization Act of 1970, the Nuclear Regulatory Comission is hereby submitting a statement
- on the Comission actions being taken with regard to the recommendations made by the Comptroller General of the United States in a report entitled
" Placing Resident Inspectors at Nuclear Power Plant Sites:
Is It Working?".
The Comission's response to the GAO Report is enclosed.
Sincerely, John F. Ahearne Chairman
Enclosure:
Responses to GA0 Report cc w/ enclosure:
The Honorable Alan Simpson 8004240 200
NRC RESPONSE TO THE REPORT On November 15, 1979, the Comptroller General issued a report to the Congress of the United States on'the Nuclear Regulatory Commission's Resident Inspec. tor Program. This report, entitled " Placing Resident Inspectors at Nuclear Power Plant Sites:
Is It Working?", makes five recommendations to the Chairman of the Nuclear Regulatory Commission. Actions taken concerning these recommenda-tions are as follows:
1.
Recommendation - Require that resident inspectors ' perform more direct observations than review of records and provide inspectors with more administrative support.
NRC Action A restructuring of the expanded NRC inspection program for operating and preoperational reactors is underway. This reworking will require more direct observation and independent measurement of licensee activities than review of records. As a result, the Senior Resident Inspector at each site will be devoting a substantial portion of his inspecting activities to direct observation or to independent neasurement. The other resident inspector or inspectors at each site will be performing essentially all of their inspections by direct observation or independent measurement.
The program for resident inspection at reactor construction sites is being modified to similarly emphasize direct observation and independent measurement.
Part-time clerical positions are being assigned to each resident office.
These clerical personnel will assist the resident inspector (s), relieving them of some administrative burdens and providing services previously available only from their Regional Offices.
2.
Recommendation
" Define the role of the resident inspectors and establish what qualifications and training they need, specifically requiring them to have plant-specific training, and a level of training comparable with a reactor operator."
NRC Action The scope of duties, responsibilities and authority for resident inspectors has been conveyed to these inspectors, primarily through the Fundamentals of Inspection Course in the NRC training program.
A forral statement on the resident inspector's role in performing an integrated, regional-and resident-based inspection program was prepared in February,1980. A similar statement on the resident's role in responding to incidents was also prepared in February,1980.
The training and qualifications needed to become a senior resident inspec-tor were defined in 1978. Other than for some minor modifications these criteria continue to'be followed today and for the foreseeable future.
We provide up to two years of training and inspection experience to new inspectors who already possess solid qualifications in reactor operations or reactor construction but who have little or no direct experience with the NRC regulatory program.
The training programs and qualifications needed by the additional resident inspectors at a site are different because of their more limited duties and responsibilities. These inspectors must receive training in regulatory matters and inspection techniques. We expect to provide one year of training and NRC work experience to these new inspectors when they already possess experience in. nuclear operations.
If they do not have this experience a longer training program wil.1 be necessa ry. The Resident Inspector Operations Training Program has been expanded from 8 weeks to 11 weeks. ' Included in the additional training is more time on the reactor simulator, detailed discussion of the safety importance of plant auxiliary systems, and increased emphasis on reactor transients. Additional courses will also be pro-vided to improve understanding of the safety analysis of the plant
.from an engineer's point of view.
All resident inspectors are provided plant-specific training.
Much of this is obtained in their study of plant FSAR's, technical speci-fications and other written documents and in their repeated observa-tion of plant activities.
Only upon completion of such training, are they fully qualified to perform the duties as resident inspectors for that unit.
It is not our present intent to require that resident inspectors be licensed reactor operators; but they will receive training that will achieve substantial comparability to the knowledge level of the average senior reactor operator.
3.
Reco:cendation
" Assign resident inspectors to those reactor sites that are most in need of regulatory attention."
NRC Action In consonance with the President's December 7 nessage on the Kemeny Commission Report, we are accelerating implementation of the Resident Inspector Program. By June, 1980 each site with an operating or preoper-ational reactor will have the equivalent of at least one resident inspec-tor.
All such sites will have a full complement of at least 2 resident inspectors by September 30, 1980. The number of resident inspectors will increase from 46 at 34 sites as of December,1979 to about 130 for 60 sites as of September,1980. Subsequently, resident inspectors will be assigned to reactors as they reach the preoperational stage.
Since we plan to have resident inspectors at all operational and preoperational sites by September 30, 1980, we do not believe there is a need to prioritize such sites.
However, if it becomes apparent that we cannot meet this goal, the sites will be manned in priority order.
By June,1980 NRC resident inspectors will be assigned to the 16 sites where construction activities are in the crucial final period. NRC resident inspectors will also be assigned to sites in earlier stages of ccnstruction where oroblems are evident. There are four positions bud;eted for such assignments. Additional constructic~ sites wil.1 be manr.ec as qualified resident inspectors become availeole. We are hoping to ran three or four such additional sites by September,1980.
4.
Re:omendation
" Coordinate the interface between the existing iEcional inspection approach and the evolving inspection approach."
NRC Action An ftP.C task force is developing an integrated, ro0 tine inspection prcgram for preoperational and operating reactors. They are incorporat-int reconnendations from current Regional and resident inspectors, inspector supervisors, and the various studies of the Three Mile Island accident. The first step, temporary instructions controlling and integrating these efforts, was issued February 7.
The final product is to be issued by October,1980.
5.
Recomendation "Reevaltjate.and restructure ~the performance appraisal team and develop appropriate goals and measures of effectiveness for its (fiRC's) nuclear power plant inspection program."
f;RC Action h'e have recently concluded an evaluation of the perfonnance appraisal team, one that included both an in-house review and an independent contractor's assessment. We are considering alternatives relating to the location of the staff organizationally and physically.
In addition, em;hasis is being placed on staffing and policy development. The per-formance appraisal function has been given high priority relative to the other programs of the Office of Inspection and Enforcement.
The f;RC Special Inquiry Group ("Rogovin") reconinended "a team or blitz approach, in which a number of inspectors make unannounced visits from P,egional headquarters to conduct in-d' pth inspections of the overall e
operation of a plant for at least a week or more, perhaps accompanied by their supervisor or by project management personnel." The perform-an:e appraisal team provides a limited version of such blitz inspections with emphasis on quality control management at the plant and at licensee co porate headquarters.
Consideration is being given to expanding this cu rently limited app. roach to provide a comprehensive inspection of overall plant operation.
At e pts have been made in the past to develop appropriate goals for the nu: lear power plant inspection ')rogram, and also to develop assessment er:cedures to measure the effectiveness of the inspection program towards at.ievement of those goals. The attempts were unsuccessful. The diffi-
- v' ties of defining goals more specific than the overall regulatory goal of assuring public health and safety, and of specifying means to measure Or:g ess towards those goals, are well known and have been cited as a
.a.'c-reason for the lack of past progress in this area.
While we appre-
- iite -he difficulties of the task we do not view them as insurmountable ard :elieve that with concerted effort and the revised attitudes that ha te resulted fro, the cxperiences of the past year, appropriate goals
_4 and assessment measures can be developed. We plan to have an organi-zational element within the Office of Inspection and Enforcement, whose principal responsibility will be overall inspection program development and the auditing of its implementation, address this problem on a priority basis. We believe a successful program can be established if the proper resources are assigne~d to the effort.
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