ML19296B251
| ML19296B251 | |
| Person / Time | |
|---|---|
| Issue date: | 01/03/1980 |
| From: | Ahearne J NRC COMMISSION (OCM) |
| To: | Randolph J SENATE, ENVIRONMENT & PUBLIC WORKS |
| Shared Package | |
| ML19296B252 | List: |
| References | |
| NUDOCS 8002200330 | |
| Download: ML19296B251 (18) | |
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UNITED STATES
. NUCLEAR REGULATORY COMMISSION 2
o hY E
WASHINGTON. D C. 20555 k **U c' CCRb January 3, 1980 CHAIRMAN The Honorable Jennings Randolph, Chairman Conmittee on Environment and Public Works United States Senate Washington, D. C.
20510
Dear Mr. Chairman:
Enclosed is our reply to the questions raised in your letter of November 20, 1979 dealing with the conclusions of the Comptroller General's report, Placing Resident Inspectors at Nuclear Powerplant Sites:
Is It Working? We have prepared our response in a format that addresses each of the questions raised in the report.
We appreciate the opportunity to respond to some of the issues which that report raised.
In this connection, the report discussed financial hardships associated with relocation of our inspectors.
It concludes that NRC must give immediate attention to these financial problems if it hopes to make the resident program a success. We are concentrating on the solution to these problems and it appears that legislation may be necessary before NRC can deal totally with them. We expect to reach a decision on this matter shortly and plan to send forward any necessary legislative proposal early in the next session of the Congress.
Sincerely, JJJ]g (John F. Ahearne
Enclosure:
Answers to Questions cc: Sen. Gary Hart Sen. Robert T. Stafford Sen. Alan K. Simpson R 0 02200 ",4 3 3 O
Questions #1 - 3: The code of conduct adopted by the Commission to assure objectivity of resident inspectors may be so strict, according to the report, as to cause employee discontent and to discourage would-be applicants for the position.
For example, resident inspectors and their families are required to avoid all social contact with plant employees while "such persons may be the only people in town that possess similar backgrounds and interests."
(1) Does this requirement seriously hamper NRC recruitment efforts?
(2)
Is this requirement enforceable?
(3) Can alternative measures be taken to assure objectivity? For example, could the regional inspection force be augmented to provide resident inspectors on a rotating basis, who would be assigned to particular sites and units for short periods (perhaps one month), instead of the three-year period of residence now required?
Answer:
The potential for a loss of objectivity has been one of our most serious concerns regarding implementation of the resident inspector program. This potential is inherent in a situation where an inspector is in contact with a single licensee on a continual basis while contact with his or her NRC peers is infrequent. We have initiated a variety of mechanisms to limit and identify losses of objectivity. The code of conduct adopted for NRC's resident inspectors was written to provide the proper distance between the licensee and the resident inspector. As the GA0 noted, the code of conduct is one of the primary tools used to assure that objectivity is maintained.
It does not prohibit all social contact with plant employees.
It prohibits close contact with licensee employees on a personal basis but does not prohibit the more distant and less personal contact that would flow from joint service or attendance at community, educational, and religious functions.
It sensitizes resident inspectors to avoid situations that might appear to compromise his ability to function in an objective manner.
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Answer to Question 1:
prospective NRC resident and senior resident inspectors are informed about the code of conduct and its purpose. They understand that it may preclude some potential social contacts but should not limit the way they live.
There is no evidence yet that this code is a cause for recruitment problems nor have we had complaints from current resident inspectors, except for the provision limiting participation in licensee car pool or bussing services.
Answer to Question 2:
Yes. The requirements of the code are incorporated into NRC's Inspection and Enforcement Manual.
If an inspector violates one of these requirements, he or she is subject to appropriate action.
Answer to Question 3:
Loss of objectivity is of definite concern in the Resident Inspection program.
In our judgment, the objectives of the existing code of conduct are appropriate and necessary to assure the credibility and objectivity of the resident inspectors.
In addition, the Office of Inspection and Enforcement has initiated
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a variety of other mechanisms to limit and identify losses of
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objectivity, including selection cr iteria for inspectors, audits by a Performance Appraisal Team, training and retraining which emphasizes the need for objectivity, limits on the period of assignment at a given site and frequent contact and oversight by Regional supervisors.
Further, a very effective way of assuring against loss of objectivity is to provide a peer with whom the resident inspector can interact.
The expanded resident inspection program will provide for a minimum of two resident inspectors at operating reactor sites.
If we adopted the concept described in Question 3, additional difficulties would be created which would reduce the quality of the Resident Inspector Program. A key recruiting advantage for resident assignments has been the minimization of travel for the inspector as compared to his regional inspector counterpart who is away from home every other week. A one-month rotating assignment would further hamper recruitment for such region-based inspection assignments.
Furthermore, a major advantage of the Resident Inspector Program is that the resident inspector becomes very knowledgeable about the specific plant to which he is assigned. This detailed know-ledge could not be obtained in one month rotations.
4-Question 4:
From what is known of the results and conclusions of these evaluations, does the Commission see a need for 24-hour coverage by resident inspectors at nuclear pcwer plants?
Answer:
Presently we are working toward providing resident inspector coverage at all units. We have not reached the point where we believe it is necessary or desirable to have 24-hour coverage.
Having 24-hour coverage would require resources substantially (perhaps by a factor of 3 or more) beyond that which we presently envisage and would present difficulties in finding qualified individuals. However, our current program is not incarsistent with the establishment of continuous 24-hour coverage if it is shown to be necessary or desirable in the future.
It should be noted that we now require that some inspections be performed periodically on night shif ts and on weekends.
h
- Question 5:
Can the Commission enhance the element of surprise in regional inspections to offset the factors cited by GA0 in support of its conclusion that unannounced inspections have become less important? For example, can such inspections be made less predictable?
Can prompt entry to the plant be assured?
Can the prompt availability of key plant records and personnel be required?
Answer:
The Commission agrees with the GA0 conclusion that unannounced inspections by the regional office are less important where a resident inspector is present.
The resident inspector has daily opportunities for unannounced inspection of any licensee activity taking place. We are currently evaluating whether resident inspectors take full advantage of this surprise element in their daily routine and how regional inspectors can best support this approach. Resident inspection experience should identify opportunities for directing region-based inspection effort, including surprise inspections. With the thorough site knowledge gained by resident inspectors, strategies for unannounced region-based inspection could be directed to assure that they are less predictable than they were in the past.
Prompt entry to the plant is assured for resident inspectors and for other NRC inspectors who complete appropriate, site-oriented,
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licensee-provided training. While some region-based inspectors could obtain such prompt entry status at a specific site, it would not be realistic to expect every region-based inspector to have access to every site in his region.
Prompt availability of plant records and personnel is already required when they are already on site.
Records kept at other locations must be provided upon request.
- Question 6:
Since regional inspection teams are characterized by an inter-disciplinary approach, in contrast to the more limited expertise of resident inspectors, how can the presence of resident inspectors make unannounced regional inspections less important?
Answer:
Unannounced inspections are not less important now than they were before the resident program was initiated.
Then, the unannounced inspections were limited to the specific areas which inspectors reviewed when they visited the site on an unannounced basis. Now, unannounced inspections include the combined efforts of both resident inspectors and region-based inspectors.
The resident inspector has daily opportunities for unannounced inspection of any licensee activity taking place.
Thus, unannounced routine regional inspections are less important at sites where resident inspectors are located.
Furthermore, resident inspectors can also identify areas in which region-based efforts, including their unannounced inspections, can be carried out most effectively.
- Question 7: What are the Commission's views of these findings by GA0 and what efforts, if any, does NRC have underway to better define the role of the resident inspector?
Answer:
The GA0 Report raises the question of wheuier the resident inspector's primary role is to institute immediate alleviation of a problem or potential problem or to observe licensee actions and report on them to NRC's regional office and headquarters.
The principal roles of the resident inspector, as any other inspector, are to enhance and, to the extent possible, to assure safety.
Whenever any inspector observes or finds any condition adverse to safety, he is charged with the responsibility to promptly discuss his observations and concerns with the licensee. These discussions with licensees are not inconsistent with our position that inspectors must not make decisions for licensees. Moreover, the inspector is also charged with promptly informing his supervisors of his concerns so that if formal action, such as an NRC Order, is needed, it can be effected promptly.
In an accident situation, the resident inspector is charged with two principal roles.
They are:
(1) assessing the adequacy of licensee actions; and (2) providing information to the NRC.
If the inspector sees something he believes is wrong, he is expected to promptly point out his observation or conclusion to responsible licensee personnel.
He will also discuss his concerns by telephone with the NRC operations center.
If appropriate licensee action is not taken, any necessary orders will be directed to the licensee from NRC headquarters.
- Despite the fact that the foregoing description has been our position on the matter, we agree with the thrust of the GA0 report and we plan to reexamine the role of the inspector.
It is one of the projects which we have scheduled as a result of lessons we have learned from the Three Mile Island accident.
Work is well underway on this topic.
-9 Question 8:
Should the inspector advise plant personnel to remedy the violation in advance of citing it?
Answer:
Inspectors are expected to advise licensees promptly of their belief that violations are occurring or about to occur.
In no case should a licensee first learn of a violation through a written citation. We expect that one advantage of resident inspection will be the identification of incipient problem areas before they degenerate to instances of noncompliance with require-ments.
The resident inspector is expected to call these to licensee management's attention for prompt corrective action.
. Question 9:
Does this depend on the potential seriousness of the violation?
Answer:
No.
Question 10:
If the Commission's original plans on training and qualifica-tions of " site" inspectors were retained and extended to " unit" inspectors, how long would full implementation take?
desirable?
Is such a requirement necessary or Answer:
As part of our original plan for " site" inspectors, we planned to provide two years of training and inspection experience for new inspectors who possess solid qualifications for reactor operations or reactor construction but who have had little or no direct experience with the NRC regulatory program. We did not require two years' training for fully qualified, experienced inspectors before assigning them as " site" resident inspectors.
If we set a similar requirement of two years of training before assigning " unit" resident inspectors to a site, our implementation schedule would be as follows:
-- FY 1980 - Hire and initiate training FY 1981 - Commence assignments FY 1982 - Complete implementation of the expanded program This would represent a delay of about 2 years.
NRC does not believe that it is necessary or desirable to provide the same training program for " unit" inspectors as it is providing
" site" inspectors. Unit inspcctors have more limited duties and responsibilities, primarily oriented to repeated direct observation and independent measurement of licensee activities. Nevertheless, Unit resident inspectors must receive training to provide them with the necessary regulatory capability and appropriate inspection techniques.
- We do not plan to hire Unit resident inspectors without actual experience directly from college or graduate school.
There may be exceptions but these individuals would have to have extraordinary qualifications and might be subject to a longer training program.
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=O Question 11:
Given the disparity between current plans on training and qualifications of unit resident inspectors and the training and qualifica-tions of licensed reactor operators, is accelerated implementation of the program still worthwhile?
Answer:
We believe that the current implementation schedule will provide qualified resident inspectors capable of meeting the goals of the program.
It is not our present intent to require that unit resident inspectors be qualified as licensed reactor operators.
We are in the process of upgrading our training program for new inspectors. One of the objectives of that program is to provide inspectors with a knowledge level comparable to that of a licensed reactor operator.
Practical operating experience will be obtained primarily through observation training at reactor facilities.
Question 12:
What plans does the Commission have to prioritize sites for future assignments?
Answer:
The early assignments within the resident inspection program were based on considerations of utility performance. Our goal now is to have resident inspectors at all nuclear plants in preoperational or operational status by September 30, 1980.
Subsequently, we will assign resident inspectors to reactors as they reach preopera-tional stage and continue with the resident program from then on.
However, should significant problems arise at a site for which there is not now a resident inspector, we would promptly dispatch an inspector to provide full-time presence.
Assuring that the plant is constructed in accordance with both its NRC-approved permit and with well-established engineering practices is critical to granting an operating license.
By the end of FY 1980, NRC resident inspectors will be assigned to all sites where the construction activity is in its crucial final period. At that time, there will be 16 such units.
Early in this period the reactor vessel and safety system piping are installed.
Later in this period, the measurement and control systems are installed.
NRC resident inspectors will also be assigned to sites in earlier stages of construction where problems are evident. There are four such sites designated for such staffing in Fiscal Year 1980.
Additional construction sites will be manned as qualified resident inspectors become available. We are hoping to man 3 or 4 such additional sites by the end of this fiscal year.
At least half of the construction sites will be manned by the end of Fiscal Year 1980. This percentage will rise in future years.
- Question 13: Has the Commission assigned resident inspectors to construction sites where significant irregularities have been alleged, such as Marble Hill, Indiana, and Bay City, Texas?
Answer:
Yes, resident inspectors are assigned to construction sites where significant irregularities have been alleged.
I.1 particular, resident inspectors are assigned to the sites in Marble Hill, Indiar,a and Bay City, Texas.
In addition, another 10 resident inspectors are assigned to 10 other construction sites and 7 additional individuals have already been designated for such assignment by September 30, 1980.
- Question 14: What steps has the Commission taken to define the respective program roles and to avoid duplication of effort?
Answer:
We consider that we have one inspection program in which the resident and regional contributions are complementary. We are currently revising our program definition to avoid duplication of effort.
The revised description will state which parts are to be performed by region-based inspectors and which by the resident inspectors.
Question 15: What steps has the Comission taken to maximize direct observa-tion, as opposed to review of records by resident inspectors and by regional inspection teams?
Answer:
As mentioned above, a reworking of our routine inspection pro-cedures is undemay. This reworking will emphasize direct observa-tion and independent measurement of licensee activities.
Direct observations will include:
a.
Verifying the adequacy of management and procedural controls and staff discipline for conduct of day-to-day operational and surveillance activities, b.
Verifying that valves and switches are properly positioned.
c.
Following up on completed maintenance work orders to assure proper lineup of equipment.
d.
Observing surveillance tests to determine whether test instruments are properly calibrated and that approved procedures are followed regarding taking equipment out of service during the test and returning it to service af ter the test.
e.
Verifying that the licensee is complying with technical specifications and operating parameters.
f.
Observing routine maintenance to detect such things as the wrong lubricant, improper tightening of valve packing, substitution of unqualified parts and lack of care in the protection of open systems.
g.
Inspecting terminal boards, panels and instrument racks for unauthorized jumpers and bypasses and checking locations against records to ascertain whether jumpers were removed as stated in the records.