ML19308B957
| ML19308B957 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/30/1977 |
| From: | Conver S, Ledoux T, Volgenau E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19308B949 | List: |
| References | |
| TASK-TF, TASK-TMR SECY-77-138A, NUDOCS 8001170662 | |
| Download: ML19308B957 (60) | |
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O' STUDY REPORT NRC INSPECTION ALTERNATIVES I
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission April 1977 Prepared by:
viewed by:
Stephen K. Conver i
John C. LeDoux
. Edward E. Legasey Christine Rehfuss JphnG. Davis,DeputyDirector Office of Inspection
. Study Group, Office of the Director and Enforcement Office of Inspection and Enforcement Approved by:
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Ernst Volgenau Director Office of Inspection and Enforcement w
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V Contents I
INTRGOUCTION........................
1 Background......................
1 NRC Safety Assurance Program.............
2 The NRC Inspection Program..............
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, Improving the. Current Program 4
II DESCRIPTION OF INSPECTION ALTERNATIVES 8
Alternatives.....................
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Components of Alternatives..............
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Inspection Alternatives....,..........
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III EVALUATION OF INSPECTION ALTERNATIVES..........
15 Introduction....................
15 Evaluation Criteria
................15 Qualitiative Evaluation 17 Quantitative Evaluation 21 IV CONCLUSIONS.......................
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IMPLEMENTATION REQUIREMENTS...............
29 Introduction....................
29 Resource Requirements / Phasing............
29 Implementation Planning................
32 APPENDIX A RESOURCE REQUIREMENTS FOR ALTERNATIVE 1-5 APPENDIX B INSPECTOR ONSITE PRESENCE APPENDIX C PHASED MANPOWER - ALTERNATIVE 3 b
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.SECTION I INTRODUCTION i
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In June 1974, the Office of Inspection and Enforcement (IE) initiated a Trial Program to evaluate the concept of assigning inspectors to locations near nuclear power reactors. This two year program involved the assign-ment of two NRC inspectors to locations from which they were able to inspect a total of four reactor sites.
The evaluation of this Trial Program concluded that the concept of resident inspectors is viable because it can provide a number of significant benefits, principally involving the, efficient and effective use of an inspector's time.
IE's efforts in pursuing various resident inspection concepts are consistent with the stated interests of the new Administration in n
improving federal oversight of the nuclear industry.
This paper describes and evaluates four alternative resident incpection concepts H
vis-a-vis the current program, identifies the concept of full-time onsite inspectors as a preferred altarnative, and describes the tasks necessary to implement this preferred alternative.
Background
The basis for licensing and regulating nuclear facilities is found in the Atomic Energy Act of 1954, as amended, which established private owner-ship and government licensing of nuclear facilities.
The Act also prescribed that such-facilities are subject to Atomic Energy Commission (AEC) requirements to protect the public health and safety.
This regulatory authority of the AEC was transferred to the Nuclear Regulatory Commission (NRC) by the Energy Reorganization Act of 1974.
The primary safety consideration in the operation of any nuclear facility is the control and containment of radioactive material under both normal l
and accident conditions.
Since the potential consequences of significant I
exposure to radiation are large, its risks must be kept as small as possible.
A number of controls are established for this purpose.
The industry and the NRC have complementary roles in providing these controls and in ensuring that they are maintained., The NRC establishes rules, regulations, standards and guides for the construction and opera-l tion of nuclear facilities.
The licensee has the direct responsibility to design, construct, test and operate a facility in a safe manner. The NRC, through its licensing and inspection programs, provides reasonable assurance that the licensee is fulfilling this responsibility and that the health and safety of the public are protected.
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NRC Safety Assurance Program 4.
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An adequate level of nuclear reactor safety is achieved and maintained because plants are properly designed, constructed, operated and main-tained using applicable standards and quality assurance practices.
The NRC standards, licensing and inspection programs assure that these important elements of safety are appropriately addressed over the lifetime of a reactor.
These NRC activities integrate meaningful requirements, thorough safety review by both the licensee and the agency and continuing periodic inspection by both groups.
In safety reviews, NRC emphasizes the licensee's system design for fabrication, construction and quality assurance.
In inspection, NRC emphasizes licensee management control of these activities.
The underlying philosophy of the design of facilities and the NRC safety l
review is defense-in-depth, or multiple levels of defense against acci-dents.
Defense-in-depth provides three primary levels of protection.
g First, the plant is designed to prevent accidents through intrinsic design featurep, quality components and construction, and redundant sys-tems and controls.
Systems essential to safe control are designed to automatically revert to a safe state during adverse conditions. The second level consists of safety systems that protect operators and the public by preventing incidents or minimizing damage should those incidents occur.
The third level of safety consists of additional safety systems to accommodate severe hypothetical accidents that involve independent failures of the redundant protective systems at the same time as the accident th?y are designed to control.
In sumary, nuclear facilities are protected by exacting standards of design and construction, independent safety systems and redundant safety systems to prnvide protection in the unlikely event of multiple failures. Additional protection is provided by highly trained reactor operators.
The NRC Inspection Program Inspections during the licensing process are part of NRC's acceptance of applications and the issuance of construction permits and operating licenses.
Inspections continue thereafter throughout the operating life of a nuclear facility.
Prior to construction, the inspection program concentrates on the applicant's establishment and implementation of a quality assurance program.
Quality assurance comprises all the systematic activities
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that are necessary to provide adequate. confidence that a key structure, system or component will perform satisfactorily in service.
Inspections cover quality assurance activities related to design, procurement and s
the plans for fabrication and construction.
An acceptable inspection finding is a prerequisite for NRC's docketing of an application for review and subsequently, for issuing a construction permit.
During construction, a sampling of licensee activities is inspected to make sure that the requirements of the construction permit are followed and that the plant is built according to design and applicable codes and standards.
Construction inspections look for sound management, qualified personnel, quality material, conformance to approved design and for a well formulated and satisfactorily implemented quality assurance program, since these factors are most important to the successful construction of a nuclear plant.
The licensee's implementation of these factors is 9
assessed by examination, on a spot check basis, of construction activities.
As construction nears completion, preoperational testing to demonstrate the operational readiness of the plant and its staff begins.
Inspections during this phase determine whether the licensee has developed adequate test plans, assure ~ that tests are consistent with NRC requirements and determine that the plant and.its staff are prepared for safe operation.
Inspections durina the preoperational phase involve (1) reviewing overall test management procedures; (2) examining selected test procedures for technical adequacy; and (3) witnessing and review of selected tests to determine their outcomes and the consistency of planned and actual tests.
In addition, inspections review the qualifications of operating person-nel and assure that operating procedures and quality assurance plans are developed.
About six months before NRC's operating license is issued a startup phase begins in preparation for fuel loading and power ascension.
Following the issuance of an operating license, fuel is loaded into the reactor and the actual startup test program begins. As in pre-operational testing, NRC inspection emphasis is placed on test management procedures and results.
The licensee's startup test management system is examined, test procedures are analyzed, tests are witnessed and licensee evaluations of test results are reviewed.
When startup testing is completed satisfactorily, routine operations begin. Thereafter, NRC continues its inspection program throughout the operating life of the plant to verify that the licensee's control systems assure the safe operation of the plant in compliance with NRC requirements.
Specific elements of the operating reactor inspection program are:
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Reviews of the basic systems--and pratced i
technically sound and are implemented properly.
Analysis of records of licensee operation and interviews of personne1' to confirm that actions called for by the prescribed systems and procedures are routinely followed.
Periodic verification of licensee and system performance i
by means of independent NRC observations, tests or measure-ments.
Additional insoe_ction activities are also conducted.
i quality assurance program and the operating staff. exam l
i Licensee Event Reports; facilit The i
details; refueling activities; y operating procedures; y also examinetrain I
I testing, calibration and maintenance activities. spent fuel shipments; and func i
defined inspection activities, approximately 20 In addition to these 1
site time is scheduled for conducting unprogramm% of an inspector's on-of the plant or examining specific areas of interest or concern.ations ed direct observ inspectors also conduct detailed inspections and investi NRC specific areas as a result of apparent plant weaknesses,gations in allegations.
events or assurance that public health and safety are pr licensee activities throughout a nuclear facility's lifetime.
implemented; that' plants are constructed prop Tc do this i
i are conducted and results are acceptable before routine operation i
and that the plant is operated safely.
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_ Improving the Current Program The current inspection program has evolved over the past twenty the nuclear industr public have grown. y, safety technology and the safety awareness of the safety cannot be inspected into a plant.The inspection program reflects Rather of conservative design, quality components, prope,r construction andsa testing The prop,er role for inspection is to assure that these maintained.
on licensee control activities.In keeping with this philosophy, the N gement through quality assurarice programs and systems, ra j
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acceptance of components and hardware systems..; If licensee activities are properly controlled and conducted, then the resulting systems should
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function so that the safety afforded by the defense-in-depth design of the facility will be realized.
This philosophy is at least partially responsible for the excellent safety record of the nuclear industry.
The current program normally is conducted by inspectors or teams of inspectors operating from five 'legional Offices, performing periodic inspections at licensee sites. About 25% of an inspector's time is spent onsite inspecting licensee activities while most of the balance is spent in the regional offices preparing for inspections, evaluating inspection findings, and documenting inspections performed.
Since on-site time is limited, there is limited opportunity for direct observa-tion of licensee activities, and the current program must place i
considerable confidence on the accuracy and completeness of licensee statements and documents that attest to those licensee actions i
I performed without NRC direct observation.
Because of the reliance placed or, these licensee statements and documents, it would be prudent to increase confidence in their accuracy and completeness.
By expanding verification of licensee actions, NRC would have more confidence in licensee records and could more readily assess the safety of licensee activities.
This post-performance ' audit would consist of the NRC or its contractors verifying the accuracy and completeness of the licensee records through an independent program of direct measurement.
In addition to this post-performance verification, more direct observation of activities underway at licensee sites should increase NRC confidence that the licensee control systems produce proper actions.
In addition to providing an independent assessment of licensee performance, the inspection program today is thought to provide a positive incentive for proper licensee performance.
This incentive is apparently based upon inspector presence onsite and licensee uncertainty as to what is to be insoected.
The Trial Program evaluation concluded that licensees place greater emphasis on regulatory requirements as association between NRC inspectors and plant staff is increased.
More inspector presence on-site should therefore encourage improved licensee understanding and awareness of regulatory requirements.
Increasing the time an inspector spends onsite provides more opportunity for directly observing licensee activities and assessing the overall safety condition of the plant.
Because of the improved familiarity with a specific plant that would result from more onsite time, an inspector, in addition to detecting instances of noncompliance with regulations, would be better able to assist in identifying potential problem areas before they developed into safety hazards. Therefore, increasing onsite time would result in a higher level of confidence that licensed activities are conducted safely.
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C The existing NRC inspection program provides an adeqate technical basis upon which to assure the safety of licensee operations.
The improvements identified above would strengthen this technical basis and, at the same time, add an important benefit by increasing the public perception of the adequacy of the NRC inspection program.
Regardless of its technical basis, an inspection program that fails to convince the public of its adequacy will continually be the subject of controversy and suspicion.
Criticisms of the existing inspection program follow three consistent themes:
(1) there.are too few HRC inspections; (2) inspectors spend too little time actually at the plant; and (3) even when onsite, inspectors spend too much time reviewing paperwork as opposed to observing actual work or observing and conducting tests and measure-I ments.
A decided move by HRC into more direct verification / measurements and refining the program to provide more onsite time enhances the base for NRC technical jud to those criticisms. gments and, at the same time, effectively responds These changes are expected to:
Increase NRC knowledge of the conditions at a licensed facility and provide a better technical base for regu-latory action.
lessen the program's reliance on the accuracy and completeness of licensee records by improving the inspector's ability to independently verify' licensee performance.
Provide additional assurance that licensee management control systems are effective and that licensee per-formance is acceptable.
Improve the NRC pt.sture relative to incident response.
As an additional benefit, the Trial Program suggests that these changes should also improve the credibility of the program in the licensee's eyes.
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The refinements introduced above fonn the basis for three goals that the NRC inspection, program should satisfy:
Establish greater NRC presence onsite at licensee facilities.
Increase the direct observation of key licensee activities by NRC inspt tors.
Enhance the confidence in licensee records by increasing NRC direct verification / measurement activity.
The sections that follow identify and evaluate four alternatives that the Office of Inspection and Enforcement could pursue to achieve these l
goals.
Each of these alternatives preserves the underlying philosophy of NRC regulation and inspection.
The licensee would continue to be directly responsible for designing, constructing, testing, and operating the facility in a safe manner.
NRC inspectors, whether stationed onsite or in Regional Offices, would remain independent of the licensee's control systems while assuring that the licensee was providing adequate protection.
Finally, each of the alternatives maintains the present.
scope of responsibilities of the Office of Inspection and Enforcement involving the evaluation of licensee periormance with respect to safety and safeguards matters.
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SECTION N O
DESCRIPTION OF INSPECTION ALTERNATIVES Alternatives Five alternatives are described that permit varying degrees of inspector presence, direct observation of licensee activities and the use of independent measurements.
The Current program, relying upon regional inspectors, is alternative 1 and is used as a baseline against which the other alternatives are compared.
The Site Vicinity concept, alternative 2, involves placing some inspectors in the vicinity of clusters of reactor sites and supplementing their inspection effort with special performance appraisal and direct verification / measurement t
teams.
Alternative 3, Full Time Onsite, calls for an NRC inspector at l
every reactor site to provide daily inspection coverage.
Alternatives 4, Continuous Onsite, and 5, Continuous in Control Room, provide extended inspection coverage and require an NRC inspector to be continuously pre-sent at the site or in the control room of each reactor with an operating license.
Each of the alternatives that places an inspector onsite would also involve in-depth performance appraisal and direct verification /
measurement inspections conducted by a skilled and diverse group of NRC inspectors.
Components of the Alternatives There are four basic components that comprise the inspection alternatives identified above.
To avoid duplication, the components are identified and discussed at a conceptual level before they are combined to form i
inspection alternatives.
The inspection components are:
Regional insoections involving NRC inspectors, either project 1
or technical support, operating out of Regional Offices (as in the present program).
Resident insoections conducted by inspectors stationed at
(,or in the vicinity of) licensed facilities.
Direct verification / measurement inspections conducted by NRC inspectors and possibly contractor personnel to observe work in progress or independently test licensee activities.
Performance appraisal inspections conducted by a select group of skilled and diverse NRC inspectors to provide a short period of concentrated inspection of any or all aspects of a licensee's operation.
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Using the regional inspection approach, NRC inspectors are located in Regional Offices and periodically travel to licensed facilities to make inspections.
In the present program, an inspector spends about 25 percent of total available time onsite at licensee facilities, and each operating reactor licensee typically receives about two inspections of two to three days duration each month, either by a single inspector or by a team composed of several inspectors.
Regional inspectors are of two main types, project and technical support.
Project inspectors are usually generalists with technical knowledge in the broad spectrum of activities conducted by the licensee.
They are responsible for conducting inspections in certain areas and for monitoring the overall inspection status of a site, coordinating the total ongoing inspection effort at the site, assuring all necessary inspection require-I ments are fulfilled and following up on all outstanding items and enforce-l ment actions.
Project inspectors normally serve as the point of contact between the licensee and the regional inspection organization.
Technical support inspectors are' specialists that possess a high degree of expertise in one or more engineering or scientific disciplines related to licensee activities.
Technical support inspectors provide coverage of specific j
technical areas and support the inspection effort of the project inspectors.
Under the current regional inspection program, inspectors examine technical procedures, management controls and licensee records and observe licensee activities. Approximately 20-30% of onsite time is spent in direct observation and independent measurement.
Using the resident inspection concept, some inspectors' would be located either at or in the vicinity of licensed facilities.
project inspectors would be best suited for resident inspector duty, because the situations encountered at the site may cover a spectrum of activities.
Technical support inspections appear more suited to regional rather than resident inspectors because the expertise of the technical specialist is more narrow than the project inspector and can be used more effectively and efficiently when applied to a number of different locations.
There are several possible variations of this approach.
If located near " clusters" of reactors, one site vicinity inspector might be able to provide inspec-tion coverage to all tne clustered facilities by spending a percentage of his time at each. Assigning one onsite inspector to each facility would permit the in pector to concentrate efforts even further.
Continuous onsite coverage for a particular facility could be achieved by assigning j
a number of inspectors to each site.
For all alternatives using resident project inspectors, technical support is still provided by inspectors from the Regional Offices.
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The concept of resident inspections was evaluated in the Trial Resident Inspection Program.
The Trial Program concluded that the concept was a viable inspection method and contributed to the effectiveness and efficiency of inspectors.
In addition to the ber.efit of increasing licensee awareness of regulatory requirements cited in Section I, a resident inspector was shown to enhance NRC awareness of facility status.
Licensee acceptance of the NRC inspector was improved which resulted in easier access to facility records and increased independ-ence of inspection effort.
Because of the results of the Trial Program, the resident concept is used as part of each alternative to the current program considered.
One of the prime functions of an onsite inspector would be to extend l
NRC onsite examination of the implementation of the quality assurance l
program through increased direct observation of the work and testing procedures.
The onsite inspectors would determine that licensee work and maintenance procedures were adequate and, by observation, verify that these activities were conducted properly and at the required frequency.
In addition, inspectors would examine events to determine the adequacy of licensee actions and reports.
Their proximity to and familiarity with a specific site would allow immediate onsite inspector response to significant events.
Although onsite inspectors cou7d not possess all the specific expertisa and skill of the regional technical support groups, they would be capable of recognizing actual and potential safety problems and, if necessary, could then refer these items to the technical support inspectors for resolution.
Independent Verification has two forms - direct observ'ation of work and confirmatory measurements.
Both types of independent verification are intended to provide credible assurance that the..censee has con-ducted various types of work properly.
Direct observation involves witnessing licensee activities in progress. This "over the shoulder" observation can be done by both project and technical support inspectors.
While the opportunities for direct observation are probably greater for resident inspectors, it is common practice for regional inspectors to observe particularly significant work in progress as part of the current inspection program.
The number and types of these observations should l
be based upon a determination of the most safety-significant licensee work units,.the degree to which this work can be meaningfully observed l
and the degree of confidence desired.
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Confirmatory measurements differ from direct observation in that they are " hands on" (as opposed to "over the shoulder") inspections.
These types of inspections involve technical verification that the licensee has done certain work properly.
Through confirmatory measurement in-spections, those licensee activities that are not subjected to direct observation by the resident inspector or specialists still are subject to direct verification by the NRC but on a post-performance basis.
1 This inspection technique can increase the NRC's confidence in the technical performance of the licensee ar.d in the accuracy and complete-ness of licensee documentation.
While some measures may be appropriate for an onsite insptction, it may not be an efficient allocation of resources to duplicate at each site the confirmatory measurement capability that involves specific technical talents and equipment.
9 Therefore, NRC inspectors supplemented by contractor technical support l
would be used as specialists to perform these technical measurements and tests.
As in the case of direct observation, the number and type of confirmatory measurement inspections would be based upon the degree to which safety-significant plant parameters should and can be verified by test or measurement and the desired degree of confidence.
Performance appraisal inspections are thorough critical reviews of licensee facilities by a select group of experienced NRC inspectors.
While the current inspection program appraises the performance of licensees, intensive performance appraisal inspections are not conducted as a part of it. These appraisals would provide an additional layer of inspection in assuring the safe operation of licensed facilities.
Inspectors would be chosen for their expertise. and experience. The specific disciplines needed on a particular team would be based on the type of facility inspected, the type of problems experienced at that facility in the past and other factors.
Performance appraisal inspections would be aimed primar 41y at the licensee's total control of plant activities.
Therefore, the orienta-tion of these inspections would be toward corporate and offsite management control as demonstrated by onsite licensee performance.
The onsite in-spections would involve detailed examination of selected areas of the licensee's activities supplemented by a reliance on the direct verifica-tion / measurement performed by the regional or resident and the technical support inspectors. The performance appraisal inspections would verify that the licensee control systems assure adequate performance in safety-related matters.
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y The teams conducting the performance appraisal inspections would examine essentially the same areas of different licensee's activities without regard to regional boundaries.
This would bring a national perspective to inspection and allow the NRC to obtain a more objective view of licensee performance and of the effectiveness of the total regulatory program.
In addition to appraising the licensees' activities, the results of performance appraisal inspections should indicate the effectiveness of the routine inspection program and provide insight into the performance of the onsite inspectors.
The frequency of performance appraisal inspections might average one per year per site, with more frequent inspection devoted to licensees with known or suspectcd problem areas.
A desirable output of these appraisal inspections would be acknowledgment of those areas in which the licensee was doing a particularly good job.
6 The timing of these inspections would be based on factors such as:
(1) the time since the last appraisal inspection; (2) licensee per-formance; (3) requests by Regional Offices; and (4) other events warranting examination.
Teams would establish specific objectives and schedules for each inspection and focus on major safety-significant areas.
The teams would prepare inspection reports with findings that would be turned over to the Regional Office for followup or for enforce-ment.
These inspections would not replace reactive inspections that the Regions would perform to respond to incidents or allegations.
Inspection Alternatives The basic components can be combined into inspection program alternatives that increase inspector presence and strengthen the program's independent verification capability.
Using the current inspection program as a baseline, this section briefly describes four additional alternatives that represent progressively increased effort.
Evalut.tions of the base-line current program and the four other alternatives are presented in Section III.
Alternative 1:
Current program. The current inspection program relies on regionally-based project and technical support inspectors.
Inspectors periodically travel to licensed facilities and each facility typically receives about two inspections per month of two to three days duration by a single inspector or a team of several inspectors.
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y Alternative 1 is used as the baseline for evaluation.
The program described in Section I would grow in succeeding years to accommodate additional facilities and workload but the technical program and inspection approach would remain substantially unchanged.
Alternative 2:
Site Vicinity Insoections. This option involves locating inspectors near clusters of reactor sites.
The recent Trial program to evaluate this concept concluded that the concept is preferred over regional inspectors for a cluster of three or more operating reactors within a radius of about 25 miles.
The Trial program evaluation also indicated that the site-vicinity concept appears appropriate for construction sites as well as operating reactors. In alternative 2, a site vicinity inspector is assumed to perform that part of the routine inspection program normally l
performed by project inspectors based in a Regional Office.
Depending on the number of reactors and number of sites in the cluster and an individual's j
technical qualifications, some technical support inspection requirements could niso be covered by the site vicinity inspector.
In addition, the site vicinity inspector would spend considerable time onsite observing and avaluating licensee activities.
Based upon projections of the number of reactor sites in various phases and locations, it is estimated that site vicinity inspectors could be placed at 11 clusters involving 21 sites in FY 81.
The site vicinity inspections would be supplemented by performance appraisal insppetions and regional technical support inspec-tions each with increased direct verification / measurement capability.
Alternative 3:
Full Time Onsite Inspections.
The third option to accom-plish the goals set forth in Section I is to locate at least one NRC inspector at each power reactor site.
For a fully implemented program, one inspector would be assigned for each reactor phase (construction, preoperational testing, startup or operations) represented at a site.
If there were more than two reactors in any one of the phases, additional inspectors would be required so that no inspector would cover more than two reactors. The onsite inspector would perform the project portion of the routine inspection program and some of the technical support portion.
The remaining technical eupport would be provided by the Regions.
In addition to conductin'3 ;ne defined inspection program, the onsite inspector would perform independent inspection, additional direct observttion and l
other evaluation of licensee activities.
The onsite inspector would maintain an office at the reactor site and would perform the duties described previously.
Work area inspections -
would be unannounced to the licensees and would be performed during non-prime as' well as prime shifts.
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Performance appraisal and confirmatory measurement inspections would also be included in alternative 3.
Alternative 4:
Continous Onsite Inscectors (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> oer day). A fourth option to accomplish the Section I goals is to locate a sufficient number of inspectors at each site with a reactor in startup or operation to provide continuous coverage of these facilities.
For reactors in construction and pre-operational testing, NRC would continue to provide the full time onsite coverage described for alternative 3.
Alternative 4 is similar to alternative 3 in all respects, except it requires a greater level of effort due to the continuous coverage in startup and operation.
Performance appraisal and confirmatory measuremert inspection would be included in this alternative.
Alternative 5:
Continuous Control Room Inspectors (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day).
l The final alternative involves placing a number of NRC inspectors in each power reactor control room to provide full-time coverage.
Inspectors monitoring control room activities on~ a full-time basis would be dedi-cated to that task and would not perform the routine inspection program or the other duties of regional or resident inspectors.
Because of the importance cf the other onsite operations such as work and maintenance activities and the testing and startup programs, the continuous control room inspector must be supplemented by an inspection program that examines the other facets of a licensee's operation.
The Regional and site vicinity inspection concepts are inconsistent with placing an NRC inspector con-tinuously in a control room.
If an NRC inspector is to observe control room operations to the degree a monitor would, then, at a minimum, an experienced generalist should probe other aspects of licensee operations to the same depth.
Alternative 4 is consistent with the control room concept but would duplicate much of the control room effort.
Therefore, the control room monitor was added to the Full Time Onsite alternative to maintain consistency and avoid duplication of work.
Alternative 5 is identical to alternative 3 with the addition of control room inspectors.
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SECTION 1II 4
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EVALUATION OF INSPECTION ALTERNATIVES Introduction The criteria that constitute the basis for evaluating inspection alternatives involve both qualitative and quantitative considera-tions.
This section defines these criteria and examines the benefits of each alternative as well as the costs.
To provide a consistent basis for evaluation, each alternative is assumed to be implemented and operating in a steady state condition by the end of FY 81.
Evaluation Criteria The Office of Inspection and Enforcement interacts with other functional l
elements of NRC and with licensees to insure safe licensee operations.
During the licensing process, NRC verifies that licensees are competent to comply with regulatory requirements.
Subsequent IE inspections deter-mine whether they are actually complying with these requirements.
instances of noncompliance are found, IE undertakes the measures neces-If sary to insure that licensees take corrective action.
Furthermore, IE identifies potentially unsafe conditions in nuclear facilities that indicate inadequate regulatory requirements, and provides feedback to licensees and appropriate NRC offices when these situations are found.
The ability of IE to detect noncompliance and unsafe conditions depends upon the type of inspection program and how it is used.
Therefore, inspection approaches and alternatives should be judged, at least in part, on how they satisfy the following criteria associated with program performance:
Competency.
Inspectors should be thoroughly familiar with the the regulatory program, technically proficient and well acquainted with the facility.
Utility.
The inspection program should maximize the inspector's capability and opportunity to observe those licensee activities that are meaningful to safety.
Flexibility.
The program should provide the opportunity for inspectors to pursue noncompliance and safety matters to a satisfactory resolution.
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Objectivity.
The program should provide for the evaluation of licensee activities without significant influence from inter-personal relations.
Correction of safety-related problems must be achieved without the involvement of inspectors in licensees' internal control systems.
Motivation of L.icensees.
The program should reinforce contin-uing licensee awareness of and attention to responsibilities to protect the public.
In this regard, the program should provide licensees with encouragement to improve and should minimize disruptions of licensee activities.
These qualitative criteria pertain to the ability of the inspection program to detect and achieve correction of instances of noncompliance and respond to other areas of concern.
However, the viability of the e
inspection alternatives also depends upon quantitative factors I
describing program benefits and costs.
These factors are:
Manpower Requirements.
Number and type of people required.
Dollar Costs.
Manpower and other program costs exprested in dollar amounts.
Program Effectiveness and Efficiency.
Measures expressed in terms of inspector onsite time.
While inspector onsite time is not a direct measure of effectiveness or efficiency, it can be used as an indicator since the Trial Resident Inspection Program concluded that increased onsite presence:
Improves inspector effectiveness through increased direct observation of facility operations.
Enhances NRC awareness of facility status.
Enhances inspector acceptance by the licensee resulting in easier access to facility records and increased independence of inspection effort.
Reduces licensee efforts required to support the inspection program.
Enhances licensee management attention to NRC requirements.
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Qualitative Evaluation This portion of the evaluation considers each of the inspection alternatives in light of the five qualitative criteria:
competency, utility, flexibility, objectivity, and motivation of licensees.
Alternative 1:
Current Program Competency.
Inspectors are highly qualified and competent and have excellent knowledge of a number of relevant tech-nical disciplines as well as the various facilities they inspect.
Formal training opportunities are ample and readily accessible and the Regional environment permits extensive interaction with peers.
Since inspectors are assigned to more than one plant, they may not be totally j
familiar with the details of each plant.
Their knowledge of plant status depends on visit schedules id telephone contacts with licensees.
Utility.
Because of travel requirements and other practical constraints, a regional inspector is able to spend about 25 percent of total available time onsite.
Further increases in onsite time would routinely require inspectors to travel one week out of every two.
The opportunities for evaluating all aspects of plant activity are limited by the amount of onsite time available.
Flexibility.
The present program of regional inspections encourages inspectors to pursue compliance and safety-related matters to resolution.
As a practical matter, however, the onsite time available limits the inspector's opportunity to obtain resolution of individual problems and allows less than 10% of the onsite time in independent inspection effort to pursue matters of technical interest outside the pre-planned program.
Objectivity.
The opportunity for loss of objectivity by regional inspection is small.
Motivation of Licensees. As shown by the Trial Resident inspection Program, licensees awareness of regulatory require-ments can be increased through more frequent interaction with NRC. inspectors. The current program does not provide much opportunity for such interaction.
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4.
v Alternative 2: Site Vicinity Competency.
Inspectors would become more familiar with the facilities for which they are responsible because they would typically spend part of nearly every day onsite. However, dispersing inspectors into a'large number of small groups would preclude day-to-day interaction with other inspectors and supervisors that contributes both to professional growth and current knowledge of regulatory requirements.
Utility. The site vicinity approach would permit inspectors to-spend a greater amount of time onsite than the regional g
inspection approach and would allow better knowledge of site activities. Moreover, inspection effort could be better I
scheduled to coincide with significant site activities.
Flexibility. The ability of the site vicinity inspectors to pursue matters of safety concern would be enchanced because of the increased onsite time, familiarity with the facility and the opportunity for non-prime work hours inspections.
Objectivity. The site vicinity inspectors would not maintain an onsite office and would spend only a portion of time at the site.
However, as the only NRC employee in the vicinity, day-to-day technical and professional interactions could be limited to those with licensee employees.
While the potential for loss of objectivity would be greater than that of th'e regional inspector, the Trial Program inspectors suffered no detectable loss of objectivity.
Motivation of Licensees.
Licensee attentiveness to regulatory requirements should be enhanced at those facilities where site vicinity inspectors are assigned.
However, a major drawback of this approach is that inspectors would be assigned to a limited number of sites that would be chosen on the basis of geographical, rather than performance, considerations. Hence, the positive benefit of this motivation would be realized only at those sites located in clusters.
Alternative 3: Full Time Onsite Competency.
Using this approach, inspectors would develop considerable familiarity with the licensee facility, since each inspector's responsibility would be limited to a single site. Without periodic reassignment of inspectors, however,
-(
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an inspector might not gain the breadt.h of experience that
\\J comes from exposure to a number of different facilities.
Furthermore, providing fomal training to onsite inspectors would pose practical logistics problems.
Onsite inspectors would also lose the daily professional interaction with NRC peers available to regional inspectors.
Utility.
Inspectors ~ would be able to conduct inspections at various times during the daily work cycle, including both prime and non-prime shift operations.
Inspector presence onsite would be significantly increased and could be j
sele' tively applied to emphasize safety-related licensee c
activities.
Inspection activities would be essentially unannounced.
l Flexibility.
The increased time onsite would provide the I
inspector ample opportunity to detect and verify correction r
of matters of safety concern.
Objectivity.
Because of the daily working relationship between inspector and licensee, this approach offers greater risk of loss of inspector objectivity than the site vicinity approach.
A closely related problem is the potential for inspector involvement in the licensee's internal decision-making processes.
As in the site vicinity alternative, the inspector might find professional and social peers only among the licensee employees.
Motivation of Licensees. This alternative w'ould provide increased inspector presence onsite and should have a positive influence on motivation. The activities available for inspection siiould be sufficient to make full and meaningful use of the inspector's time.
Alternative 4:
Continuous Onsite Competency. Alternative 4 provides inspectors around the clock at operating reactor sites. These inspectors would become familiar with a specific facility, but would suffer the same professional disadvantages identified in alterna-tive 3, with the exception that they could interact daily with a small group of NRC peers.
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The number of inspectors needed to provide continuous coverage of all reactor sites would require a s %tantial increase in the size of the inspection force.
ability of NRC to expand the inspector force to this e> wit, while maintaining high standards of quality is questionable. Also, retaining high caliber inspectors would be difficult, since many of them would be assigned relatively unchallenging duties during the non-prime shifts.
Utility.
The NRC inspection program emphasizes control by licensee management through quality assurance programs and systems. While placing inspectors continuously onsite would theoretically maximize the opportunity to detect i
noncompliance, it would not provide appreciably more per-spective to the licensee activities than alternative 3, because there is not sufficient licensee activity to fully utilize inspectors on a three shift basis.
Flexibility.
Continuous inspector presence would provide greater opportunity for prompt ettention to matters of tech-nical interest.
Objectivity. The possibility of loss of objectivity is less when a number of inspectors rather than an individual is stationed onsite because the group would provide profes-sional interaction and dissuade overfamiliarity with the licensee.
Motivation of Licensees.
Licensee awareness of and attention to regulatory requirements should be enhanced.
Alternative 5:
Continuous in Control Room Competency.
The qualifications of control room inspectors are necessarily different from those of current NRC inspectors.
While control room inspectors would need knowledge of NRC l
rules and regulations, they would also require training and experience equivalent to that of Senior Reactor Operators to meaningfully monitor control room activites.
Since control room inspectors would serve a monitoring function and rarely exercise their full professional cap-abilities, it would be difficult to maintain technical
~ 1 9
t proficiency during the ensite, tenure (despite supplemental I
training.
In addition, retaining qualified control room inspectors could prove difficult because of the nature of the job.
Utility. Only in the event that the licensed operator did not perform in a manner to assure the safe functioning of the plant would the control room inspector be called upon to act.
These instances occur infrequently. Moreover, increased inspector resources could be used more effec-tively if applied across the total plant rather then-concentrated in control room operations.
Flexibility It is not likely that these inspectors would contribute s1pificantly to IE's ability to detect and i
achieve correction of noncompliance or unsafe conditions because their activities are limited to one facet of licensee operations.
1 Objectivity.
Because of the close and constant working relationship between control room inspectors and licensed reactor operators, the possibility exists that interpersonal relations would enter into the inspector's evaluation of the safety of control room activities.
In situations where prompt and responsible actions on the part of the licensed operator are needed, the tendency may exist to consult with or defer to the NRC control room inspector those decisions that must be made by responsible licensee management.
Motivation of Licensees. The control room inspector would impact only control room personnel and could positively influence them to conform to requirements.
Quantitative Evaluation i
To provide a consistent basis for evaluation, each alternative is projected to FY 81.
Estimates of resource requirements (manpower and dollars) and onsite time are based on currently forecast FY 81 workload with each inspection alternative operating in steady state.
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Manpower Requirements. Alternative 1, the current program, relies on regionally based inspectors to accomplish the entire inspection l
workload.
Alternatives 2-5 require a mix of regional and onsite inspectors complemented by Special Inspection Teams. The manpower requirements describe the relative effort involved in accomplishing the alternative inspection programs and serve as a basis for comparison.
Appendix A describes the manpower calculations.
Table 1 summarizes these requirements.
Reactor technical support inspectors include all Pre-CP, health physics, power reactor technical support and non-power reactor inspectors.
TABLE 1 IE MANPOWER FOR INSPECTION ALTERNATIVES FY 81 I
1 2
3 4
5
~
~
~
~
~
-l REGION Reactor Tech Support 370 362 275 175 275 LCVIP 39 39 39 39 39 Fuel Cycle 63 63 63 63 63 Safeguards 90 90 90 62 90 Direction / Admin.
198 199 208 154 189 ONSITE Construction / Pre 0ps 0
3 62 62 62 Operations /Startup 0
10 71 426 71 Control Room 0
0 0
0 540 Admin. Support 0
0 0
71 71 SPECIAL TEAMS Inspectors / Analysts 0
120 120 120 120 Direction / Admin.
0 37 37 37 37 HEADQUARTERS Direction / Admin.
165 175 182 201 227 TOTALS 925 1098 1147 1410 1784 O
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l 8
.%--9 k-. W A
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ii
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The total IE manpower required under each alternative in FY 81 is shown in Figure 1 below.
Figure 1 FY 81 Manpower 1784 1410 1147 i
1098 l
925 1
2 3
4 5
ALTERNATIVES The estimated funding required to operate these alternatives in FY 81 is based on the IE Five Year Plan for Alternative 1 and computed additions to this amount for the other alternatives.
Figure 2 shows the total FY 81 dollar requirements for each alternative.
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r-Figure 2 FY 81 Dollarh (Millions) 80.5 66.9 55.4 51.3 l
43.1 i
1 2
3 4
5 ALTERNATIVES Onsite Presence Each inspection alternative provides more presence onsite. Thai e
total hours are calculated in Appendix B and are summarized in Table 2.
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' O TABLE 2 TOTAL ANNUAL ONSITE PRESENCE (Thousands of Hours) 1 2
3 4
5 Current Site ~
Full Time Continuous Control Program Vicinity Onsite Onsite Room Region Inspectors 175.0 171.0 127.5 63.5 127.0 Site Vicinity or 7.8 207.5 718.7 207.5 Onsite Inspectors 40.8 40.8 40.8 40.8 I
Special Teams l
946.0 Control Room Inspectors TOTALS 175.0 219.f 375.8 823.0 1321.2 Alternative 2 is only slightly less costly (7%) than alternative 3, but yields only 60% as many onsite hours.
In addition, it applies these extra hours to a sampling of sites based on geographic not performance criteria.
While hours of presence are increased by this alternative, the frequency of presence is increased only at the clustered sites.
~ Alternative 5 yields the greatest increase in onsite time, largely from control room inspections.
However, it is about twice.as costly as the current program.
More importantly, alternative 5 does not appear desirable because of the questionable inspector utility and because of potential interference with licensee responsibilities.
The most difficult choice is between alternatives 3 and 4.
The basic judgment involves the value of doubling onsite time versus the cost of 263 additional people. The additional expense would be warranted if the time could be used productively (i.e., could increase confidence and could be a meaningful job for a highly qualified inspector).
Since alternative 3 already more than doubles the onsite time spent in the current program, and since the full-time inspector in alternative 3 can cover all key licensee activities, it is unlikely that much more confidence would be gained by redoubling the onsite time.
Furthemore, there is a limited amount of significant activity during non-prime shifts and it would be difficult to provide a challenging job for the inspectors.
On balance, alternative 3 is preferred.
4 EN' Iw.,
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SECTION IV CONCLUSIONS O
While the current reactor inspection program has proved effective in determining that licensees have implemented systems to control con-struction, testing and operation, improvements could be made to this program that would provide a stronger basis for assuring that licensees are discharging their responsibility to provide adequate protection of the public health and safety.
These improvements would allow more caportunity for directly verifying licensee actions and for confirming tie accuracy and completeness of licensee work and documenta-tion.
In addition, increasing NRC inspector presence onsite would both heighten the licensee's awareness of NRC requirements and provide more occasion for assessing the effectiveness of licensee management controls and the safety of licensed operations.
I While each of the alternatives to the existing program provides 1
1 additional onsite time and enhances NRC's direct observation / measurement capability, the Full Time Onsite alternative is preferred.
When fully implemented, this alternative will double the onsite time provided by the current program with a 39% increase in inspector manpower and a 30% increase in total program costs.
The Full Time Onsite Inspection Program will place NRC inspectors in residence at nuclear sites under construction, in test and in operation.
By the end of FY 1980, there will be at least one inspector on each site.
By the end of the follow-ing year, additional inspectors will be stationed at sites with more than two reactors and at sites with reactors in more than one phase (construc-tion, test or operation).
Inspectors will maintain separate, government-supplied office space and administrative support.
The onsite inspectors will concentrate on directly observing key licensee activities.
Work area inspections will be random and unannounced and may occur on non-prime as well as prime shifts.
Inspectors based in Regionai Offices will perform routine technical support inspections and will be available to the onsite inspector when specific technical assistance is required.
In addition, special inspection teams will perform periodic, unannounced critical reviews of licensee facilities to assess the effectiveness of the routine inspec-tion program and provide insight into the performance of onsite inspectors.
The Full Time Onsite alternative applies uniform inspection resources to all reactor licensees regardless of geographic location.
Further-more, the total inspection program provides a balanced perspective of liceasee onsite activities; licensee management control systems as they
are demonstrated by onsite operations; and. the results of licensee actions.
This alternative recognizes the inter-related nature of all 3
licensee activ'. ties that impact on safety and hffords each one an
/
appropriate measure of inspection effort.
The significantly increased direct observation that this program affords should yield increased information that can be fed back to the Office of Nuclear Reactor Regulation for evaluation and incorporation into the licensing process.
It should be emphasized that this program will not change in any way the relationships and responsibilities of the licensing offices (NRR and HMSS) and IE for the safety of licensed facilities.
While there are many benefits associated with the Full Time Ons'ite alternative, IE recognizes that this alternative also risks compromise of inspector objectivity.
The inspection program will be structured to recognize that objectivity, 9
particularly for resident inspectors, is difficult to maintain. The likelihood and consequences of loss of the resident inspector's objectivity l
will be compensated for in several ways:
By creating a job and career management program that is professionally and financially satisfying so that the motivation for loss of objectivity is reduced.
By selecting personnel of high caliber so that professional and social pressure will work to counter loss of objectivity.
By verifying the good character of inspector candidates through background investigations.
By assuring that standards of conduct are specifically stated and clearly understood by inspectors.
By providing inspectors clear guidance as to their chuties and limits of their authority.
By close review of the work of inspectors, including onsite appraisals.
By complementing the efforts of resident inspectors with additional inspections by region-based inspectors and Special Inspection Teams under Headquarters control.
' y routine transfer of resident inspectors on a periodic.
Bbasis or early transfer if significant loss of objectivity is established.
sowT l
The implementation of this program will also have an impact on the resource requirements of other NRC offices. While these impacts are
(~^
not fully evaluated as part of this study, seVeral offices have indicated that they anticipate additional workload under this program.
The Office of Administration may require prompt augmenta-tion to assist in recruiting and implementation.
These additional requirements will be addressed as part of the implementation planning.
Initial estimates by the Offices of Administration and the Executive Legal Director are that fewer than five people each will be required.
The Office of Nuclear Reactor Regulation estimates that they will require one additional person for each ten additional inspectors to continue both formal and informal IE/NRR interaction.
Other office requirements may be felt as soon as the increase in the IE workforce has occurred.
Planning for the new program must include provisions for re-examining its basic concept and effectiveness.
While the details of this re-evaluation have not yet been defined, IE will develop a plan that l
identifies evaluation criteria and measures. An initial re-evaluation will be made within 18 months of program initiation.
Finally, while this study was directed to the reactor inspection program, there appear to be similar benefits that can be obtained at other major licensed facilities.
IE will sponsor a follow-on study of other fuel cycle facilities to evaluate the application of resident inspection d
4 0
we
SECTION V IMPLEMENTATION y
O' Introduction _
In addition to a larger work force of the Office of Inspection and Enforcement, implementation of alternative 3 involves a number of other factors that will ultimately determine the success of the program.
This section discusses the phased resource requirements necessary to achieve full implementation and identifies the planning tasks to be undertaken.
Resource Requirements - Phasing The evaluation of the five inspection alternatives assumed stea'dy state operatica of the onsite inspection program by the end of FY 81.
l By the end of FY 80, at least one inspector will be assigned full-time I
to each site. To assure FY 81 implementation, recruitment and training
~
must begin as soon as possible.
Cui rent estimates of the qualifications required for onsite inspectors and the available market indicate that a new employee must spend at least two years in the IE organization before onsite assignment.
Even then, not all will qualify but may spend additional time in a Regional Office to gain required experience.
The two years would be spent in formal training, performing regional inspections, and in 0JT at a site. ' The requirement for this two year pipeline means that people recruited in FY 78 could not be placed onsite or relieve a significant percentage of experienced inspectors for onsite assignments until FY 80.
Since onsite inspectors in FY 78 and FY 79 must be drawn from existing inspector manpower, not all sites can be manned immediately.
However, several sites will be manned by the end of FY 77 and approximately 45 full time onsite inspectors will be in residence by the end of FY 79.
The manpower requirements to phase into full implementation by FY 81 are shown in Table 3.
These requirements were derived based on the current forecast for licensing actions, a two-year pipeline for newly recruited personnel, voluntary moves of a limited number of current inspectors, an attrition rate of 5% for onsite inspectors end 15% for all others, gradual staffing of the special inspection teams and recruitment in FY 78 of the training and administrative support personnel.
A more detailed discussion of these factors is presented in Appendix C.
Using the FY 78 budget request and IE Five Year plan as a baseline, Table 4 shows the additional funding needed for phased implementation.
The salary and benefits estimates are based on the number of additional people each year, taking in,to account more frequent salary increases (step and promotion) for new employees. The travel estimate is based u
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i
- j-4 TABLE 3 PROJECTED MANPOWER DISTRIBUTION 78 79 80 81 82 83 REGION PERSONNEL 35 46 111 133 152 153 ONSITE TECHNICAL SUPPORTI 176 178 204 235 233 239 LCVIP 20 33 37 39 39 39 IN TRAINING 122 192 101 40 72 92 FUEL CYCLE 60 61 62 63 65 66 SAFEGUARDS 53 71 75 90 98 112 DIRECTION & ADMINISTRATION 147 174 180 208 244 254 REGION T0'TAL 613 755 770 808 903 954 SPECIAL INSPECTION TEAMS INSPECTORS 27 50 74 97 97 97 O
ANALYSTS 7
13 19 23 23 23
'4.
s SUPERVISION & ADMINISTRATION 8
15 26 37 37.
37 SPECIAL INSPECTION TOTAL 42 78 119 157 157 157 IE HEADQUARTERS MANAGEMENT 52 52 50 54 56 60 PROGRAM DEVELOPMENT 84 105 127 128 128 128 HEADQUARTERS TOTAL 136 157 177 182 184 188 IE TOTAL 791 990 1,066 1,147 1,244 1,299 Note: 1-Technical Support includes power reactor tech support, non-power reactor tech support, and support for incident response and 10 CFR 21 additional inspection requirements.
2
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~~
. TABLE'4. ADDITIONAL BUDGET REQUEST f
Dollars (Millions) 82 83 78 79 80 81 SALARY AND BENEFITS 2.0 3.5 5.8 6.0 6.3 6.6 TRNVEL 1.8 2.1 0.9 l.0 0.8 0.9 i
ADMINISTRATIVE SUPPORT 1.0 2.0 2.3 2.3 2.4 2.5 B.
4 i
TRAINING 0.5 0.5 0.5 0.5 0.5 0'. 5 CONTRACTOR SUPPORT
- 0. 5-0.5 2.0 2.0 2.0 2e0 TOTAL 5.8 8.7 11.5 11.8 12.0 12.5 l
4 Q
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t on the normal additional travel for new personnel and the additional travel associated with OJT for newly recruited inspectors; moves of O
inspectors to site locations; additional trave 4 to cover sites tempo-rarily until onsite inspectors are assigned; and the travel saved by placing inspectors onsite.
Administrative support estimates are based on office facilities, equipment, supplies and services for the onsite inspectors. Training estimates are based on the additional courses that will be conducted under contract.
Finally, contractor support estimates involve costs associated with validating the training and i
personnel qualifications / testing programs and providing additional confirmatory measurements support.
Implementation Planning Implementation of an onsite inspection program will require prompt and decisive action on a number of key issues.
Planning has already begun on some of these issues and, upon Commission approval, an i
intensive effort to complete them will be initiated. 'This effort 6
will involve both Headquarters and Regional IE personnel as well as representatives from other NRC offices such as ELD, ADM and OIA.
Small teams will be formed to establish work plans and schedules and to complete the tasks.
Key implementation tasks to be addressed in this effort are:
Onsite Manning Schedule Program Structure and Management Regional Organization Special Inspection Program Inspection Duties Training Recruitment Career Management Conduct of Employees Onsite Logistics Support and Personnel l
Legal Aspects of Responsibilities and Authorities Legal Aspects of Individual and Agency Liability Impact on other NRC Offices Enforcement Program Licensee Impact Program Re-evaluation The following paragraphs identify the' considerations to be addressed in each task.
Onsite Manning Schedule.
Total IE resource requirements for implementa-tion have been developed.
Each Region must perform a site-by-site analysis to identify:
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The order in which sites will be manned.
Ov Those sites that can be manned without a physical move.
Those sites that can be manned by existing Region personnel on a voluntary basis.
The nuinber of onsite inspectors by reactor phase required during FY 78 - FY 83.
The number of technical support inspectors required.
Results of th6 regional analyses must be consolidated and the total IE resource estimates must be allocated to the Regions.
I A summary of resource needs by skill type for each Region must be developed for use by the training and recruitment task forces.
program Structure and Management.
The staff must develop guidance for administering and conducting the onsite, support, and special inspection programs that defines the authorities, responsibilities and roles of the Headquarters staff, regional onsite and technical support personnel and special inspection personnel.
This guidance should cover the interplay among the components of the inspection program.
Supervisicn of remote, dispersed personnel must ensure adherence to inspection requirements, continued objectivity with respect to licensees and maintenance of inspector competency.
There must be a system of checks and balances within the program to ensure periodic in-depth examination of program effectiveness. This sytem must directly probe licensee control systems and indirectly evaluate the performance of the onsite program.
l 4
The program must ensure timely reporting of significant items by onsite, technical support and special inspectors and timely attention to and disposition of these items by Regional and Headquarters manage-ment.
Regional onsite and special inspection experience must be incorporated into the program development process.
The program must be well-defined to assure uniform treatment of comparably performing licensees but permit enough flexibility to accommodate different licensee facilities and performance.
That is, the program must be detailed enough to assure that there are no signif-icant differences in implementation among the Regions", but flexible enough to respond to unexpected situations and to account for licensee and facility differences.
i I
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Regional Organization. The growth and dispersement of reactor inspectors and the addition of a special inspection program may affect the number l
of Regional Offices, their internal organization or both. A task force will review these considerations, recognizing recent Commission interest in Regional expansion.
Special Inspection program.
The special inspection program must be structured to provide checks and balances to ensure the routine inspec-tion program is performing as intended. This component will bring a perspective to the inspection program that is oriented toward the total control of licensed activities and transcends regional boundaries.
To achieve this, the performance appraisal and direct verification /
measurement teams will conduct their activities from a support office reporting directly to the Director, IE.
The appraisal teams will be led by experienced inspectors supplemented by staff members skilled in the disciplines required for the specific
)
areas inspected. The teams will normally consist of three to five individuals who would spend about five days at a licensed facility.
~
The special inspection teams will possess independent measurement capability for verification of licensee performance.
NRC inspectors supplemented by contractor support will perform various measurements or activities for comparison with previous licensee measurements or activities. The direct verification / measurement capability will also be available to the Regional Offices to enlarge their independent measurement activity.
In addition to appraising licensee performance, the results of special inspections will indicate the effectiveness of the onsite program.
These inspections should help maintain inspector objectivity.
Duties of Onsite and Technical Support Inspectors.
The division of labor between ensite and regional technical support inspectors must ensure effective and efficient use of highly specialized technical support experts and of the onsite inspector generalists. The program should maximize the ability to directly observe licensed activities and perform some confirmatory measurements but should not sacrifice the broad view of licensee operations obtained through the review of records.
A task force has completed a first draft of onsite inspector duties for the construction, test and startup and operations phases.
Upon Commission approval, the onsite duties will be refined and complementary technical support duties developed.
In addition to the technical onsite duties, the authority and responsi-bility of the inspector must' be defined. This task will be coordinated with the legal considerations.
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- , Training.
The qualifications required for onsite inspectors and the methods 'of verifying these qualifications must _be developed.
training estimates have indicated a two-year training period. preliminary O
The program builds on the current IE training and consists of classroom and simulator activities, on-the-job training and formalized self-study programs.
ments has begun and wi.ll accelerate upon approval.The esta Recruitment.
To ensure smooth implementation, recruitment needs must be identified and coordinated with the specific phasing requirements and training schedules.
Once needs are identified, an aggressive recruitment and personnel processing (including security clearances) program must follow.
ment considerations, reimbursement expenses for relocat hours must be defined for the onsite program.
New employees must be informed of policy concerning onsite assignment to minimize attrition.
}
Career Management.
The onsite inspection program will bring personnel at different age levels and with different knowledge and work experience to IE.
to career development, several inspector classification These classifications, sequence of progression, grade levels and types of assignments must be established in a career development path.
liminary work has begun in this area.
pre-Conduct of Employees.
Assigning inspectors to often remote reactor of employees. sites presents a new set of considerations with respect to the c ance of or actual conflict of interest while minimizing pers sacrifices from inspectors or their families.
the conduct ex The NRC must re-examine on employees; pected of employees recognizing any legal constraints the impact that living in communities near licensed facilities might have on inspectors and their families; and other potential problems that could result from moving toward the resident concept.
Onsite Logistics Sucoort and personnel Administration.
The Trial administration issues related to the resident concept. Re relocation reimbursement, administrative assistanc These issues time.
in this area and will work with IE Headquarters and Adm personnel.to complete planning in this area.
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E
Legal Aspects of Responsibilities and Authorities. An initial examina-tion of the provisions contained in the Atomic Energy Act indicates that O
the onsite inspection program would not be in conflict with the j
regulatory role of the NRC. The Act also provides authority for NRC to perform the necessary studies and investigations.
However, changes to the regulations may be ' required to provide free and unaccompanied access to licensed facilities.
A more detailed review of the applicable legisla-tion and regulations is needed to determine whether all elements of alterna-tive 3 are consistent with NRC's responsibilities and authorities.
i Legal Aspects of Individual and Agency Liability.
Although the duties of onsite and other inspectors have not yet been completely defined, they may involve increased inspection responsibility and flexibility.
If so, the NRC and individual inspectors may be open to increased liability with respect to interference in licensee operations.
A careful assessment of the liabilities potentially incurred in this program must begin..
I Impact on Other NRC Offices. The implementation and operation of alternative 3 will have resource impacts on other NRC offices.
A number of offices have identified preliminary estimates of the addi-tional manpower required as a result of the full time onsite program.
As part of the implementation planning, other NRC offices must refine j
these estimates and determine the total resource impacts on their programs.
Enforcement Program.
j The onsite program may affect the enforcement program but the magnitude and nature of any impact has not, yet been determined.
The resident concept and its implications ~ for the enforce-ment program will be addressed in the cegoing contractor and in-house studies of enforcement and incentives.
Licensee Impact.
NRC must begin te inform licensees of the nature and intent of the onsite inspection program.
Licensee feedback should be secured to minimize the impact on licensee operations.
Program Re-evaluation.
While implementation planning prcceeds, a plan for evaluating p,rogram performance must also be developed.
This plan should identify criteria against which program performance can be measured and should specify the measures of performance to be evaluated.
An initial re-evaluation of the program should be performed no later than 18 months after inspectors begir: onsite assignme'nts.
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APPENDICES i
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1 I
t e
9 A
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45 t
l APPENDIX A Resource Requirements for Alternatives 1-5 For evaluation purposes, full program implementation is assumed at the end of FY 81. The current reactor inspection program requires routine and non-routine effort that is provided by project inspectors and tech-nical support inspectors.
The amount of onsite time that is required varies by phase of the program.
Table A-1 shows these requirements on an annual basis.
Manpower requirements for the various alternatives are based on the inspection manhours required and on the number of sites or reactors in various phases.
Table A-2 shows the current forecast of facilities for the time frume considered.
I g
TABLE A-1 ONSITE REACTOR INSPECTION MANHOURS PER SITE PER YEAR CURRENT PROGRAM REQUIREMENTS 1
Reactor Phase Projectl Tech Support Non-Routine HP/Envir3 Total
' Pre Cp 60 30 0
0 90 Construction Single Reactor 170 260 70 0
500 l 2 Reactors 295 450 120 0
865 3 Reactors 420 640 170 0
1230 4 Reactors 545 830 220 0
1595 5 Reactors 670 1020 270 0
1960 2
Pre 0ps/Reac'or 0
535 135 210 880 2
Startup/ Reactor 0
550 140 60 750 0perations Single Reactor 210 170 100 340 820 "
2 Reactors 315 255 150 510 1230 3 Reactors 420 340 200 680 1640 4 Reactors 525 425 250 850 2050 Note:
1.
Projects / Tech Sepport Ratios are:
.4/.6 Construction
.55/.45 Operations 2.
Two year period assumed for Preops, one year for Startup.
3.
HP/Envir - Health physics radiological protection and environmental inspections.-
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TABLE A-2 REACTORS AND REACTOR SITES BY REACTOR PHASE FOR FY78-83
~
1978 1979 19801 1991 1982 14 n Sites
, Reactor Sites Reactor Sites Reactor Sites Reactor Site beactor Sites teactor a.
U 62 61 62 55 44 40 g
o_
1 23 19 24 24 19 16 c
o 2
28 31 29 31 37 43 g
3 3-101 3
103 3
107 4
110 2
107 2
112 J
E 4
2 2
4 3
2 1
5 1
1 0
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1 14 12 16 18 21 15 6
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Totals
- 98 178 103 190 111 204 117 218 125 230 132 244
- The Sites per phase do not total to total sites due to the mix of reactors by phase at various sites.
The Site' total corresponds to all sites that have reactors in any phase 2-5.
A-3 Table A-3 combines Tables 1 and 2 show the annual onsite manhours required to accomplish the current program in FY.81.
Non-routine workload has been included with technical support because it generally requires specific skills.
TABLE A-3 FY 81 ONSITE REQUIREMENTS Non-Routine and H.P/
Project Tech Support Envir.
Pre-CP 3300 1650 0
Const 16540 31980 0
Pre-Ops 0
16080 5040 l
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Startup 0
7590 660 Operations 18795 24165 30430 Alternative 1:
Current Procram Analysis of historical manpower data shows that one inspector typically provides 500 onsite man-hours per year.
(Actual data for the past year shows 493 hours0.00571 days <br />0.137 hours <br />8.151455e-4 weeks <br />1.875865e-4 months <br />.) Dividing Table A-3 entries by this factor yields the number of inspectors needed co perform the current program (Table A-4).
In addition to this manpower, safeguards inspectors are also required at power reactors.
The number shown is taken from the current Five-Year Plan.
TABLE A-4 FY 81 REACTOR INSPECTION MANPOWER Pre-CP
~ ~ 10
~~ ~~~
- " ~ ~ - ~
Const 97 Pre-Ops 32 Startup 15 Operations 86 Environmental H. P.
72 Safeguards 38 TOTAL 350
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m This FY 81 projection of 350 inspectors for power reactors is 23 less than the projection in the current IE Five Year Plan. The difference is because of the more detailed analysis of reactors by phase shown in Table A-2.
Table A-2 was developed from a more recent Reactor Five Year Forecast than was available when the Five Year Plan was submitted.
Alternative 2:
Site Vicinity Inspections The Trial Resident Inspection Program recommended locating an NRC inspector near clusters of three or more operating reactors within a radius of approximately 25 miles.
The evaluation of the trial program further concluded that vicinity inspectors would be appropriate at a single or multi-unit facility during test and startup, and that nothing was identified to suggest that the concept would not be appli-i I
cable to reactors under construction.
In al.ternative 2, vicinity inspectors are considered when there are two or more sites in construction, test and startup, or operation within a radius of 50 miles. These criteria were chosen because single site multi-reactor inspectors are explicitly treated under alternative 3 and because the 50 mile radius is a reasonable comuting distance for periodic visits.
There are 11 clusters in FY 81 using these criteria.
Of these, eight clusters will contain sites in operation only, and three will contain sites that have reactors in various phases of construction, pre-op or startup testing, or operation.
These clusters are shown in Figure A-1.
Figure A-2 contains the geographical distribution of plants from which these clusters were selected.
Resource calculations are based upon the two types of clusters: mixed construction and operating reactors; and pure operating reactors.
One vicinity inspector is placed at each
" pure" cluster and two are placed at the " mixed" cluster.
The workload accomplished by vicinity inspectors consist of three components (1) all current program project type workload; (2) up to 50% of the current pro-gram technical support workload; and (3) direct observation and evaluation of licensee activities.
Regional manpower requirements are then based on the technical support workload that remains for these sites and the total workload for sites without a vicinity inspector.
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A-5 FIGURE A-1 SITE VICINITY CLUSTERf (t 50 fnile radius)
Phase
- 1.
Browns Ferry 1-3 5
Bellefonte 1, 2 5
2.
Connecticut Yankee 5
Millstone 1-3 5
i 3.
Dresden 1-3 5
Zion 1,2 5
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4.
Quad Cities 1,2 5
i Byron 1.2 5
I 5.
LaSalle 1,2 5
.l Braidwood 1,2 3,4 6.
Waterford 3 4
River Bend 1,2 3
7.
Cook 1,2 5
Palisades 1 5
8.
Monticello 5
Prairie Island 1,2 5
9.
Nine Mile Island 5
FitzPatrick 5
10.
Kewaunee 5
Point Beach 1,2 5
11.
Chlvert Cliffs 1,2 5
Douglas Point 1,2 2
- Reactor Phases: 2 Construction 3 Preoperational Testing 4 Startup Testing 5 Operations m
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9 NRC R.EGIONAL 0FFICES AND COMMERCIAL NUCLEAR POWER REACTORS IN THE UNITED STATES.
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A -7 Table A-5 shows the number of inspectors requ1Ned for this option.
TABLE A-5 INSPECTOR REQUIREMENTS - FY 81 " SITE VICINITY" Regional Site Vicinity Inspectors
_ Inspectors Pre-Cp 10 0
Construction 96 1
Pre-Ops 30 2
Startup 13 2
l Operations 83 8
Environmental 72 0
Safeguards 38 0
TOTALS 342 13 355 Alternative 3: Full Time Onsite Insoectors The required number of onsite inspectors is derived from the nunter of sites with reactors in distinct phases as shown in Table A-2.
Inspectors are l
placed at all sites where Pre-Ops (20) and Startup Testing (11) are in progress since these phases are very important check points.
Some pre-operational testing begins 18 months to 2 years prior to the issuance of an operating license. Construction will still be in progress at these sites.
Thus, the number of construction sites (62) shown in Table A-2 includes the 20 pre-ops sites.
In these cases it is assumed that the pre-ops inspectors will be able to cover the construction work as well.
This leaves 42 sites that have only construction in progress. An inspector will be stationed l
at each of these.
In a similar fuhion, when a plant is licensed there is l
a period of approximately one year for startup. The startup inspectors will cover the operations activity at these sites. This iaaves 60 sites where an operations inspectors must be located. This mix requires 133 inspectors at the 117 sites as shown in Table A-6.
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TABLE A-6
'ONSITE INSPECTORS - FY'81 No. Reactors / Site 1
2 3
4 Total Construction 13 27 1
1 42 Preops Testing 18 1
0 1
20 Startup Testing 11 0
0 0
11 Operations 34 22 4
0 60 TOTAL 133 The regional manpower required to complete program workload can be estimated by subtracting the workload onsite inspectors accomplish from the total program requirements shown in Table A-3.
The remain-ing workload is divided by o00 to obtain the number of regional l
support inspectors since regional inspectors spend close to 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> per year onsite. To obtain the regional workload, it was assumed that the onsite inspector for construction and operations sites could perform all of the work and 50% of the non-routine and technical support work.
For the Preeps and Startup phases, it was assumed that the onsite inspector could perform 75% of all the work except the health physics portion.
The health physics specialty work would be totally based in the Regions.
The onsite inspector would complete a n.aximum of 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> per year of the current inspection program.
Using these assumptions with the location of the 133 onsite inspectors and Table A-1 data, Table A-7 shows the annual program requirements.
TABLE A-7 FY 81 INSPECTION PROGRAM MANHOURS Reat.cor HP/Envir Tech. Supp.
Tech. Sul Phase Total Hours Onsite Hours Rcoion Hours Inspectors Insoectoi Const 48,520 12,415 27,105 54 0-Pre-Ops 21,120 10,060 11,060 17 6
Startup 8,250 5,698 2,552 4
1 Operations 73,390 25,886 47,504 30 65 TOTALS 151,280 63,059 88,221 105 72 e
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A-9 In addition to the 177 inspectors shown above, the Regions require 10 inspectors for the Pre-CP workload shown in Table A-3.
The Regions
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must also coordinate the work at the sites, regional inspections, training Headquarters assignments, and other liaison type activity. This work will require travel to each site three times per year for one week. Since an inspector can make 12 visits each year at 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per visit, one inspec-tor should be able to handle 4 sites.
For 117 sites, this would require 30 additional inspectors,11 for construction sites and 19 for operating s.tes. Table A-8 summarizes these requirements.
TABLE A-8 SITE AND REGION INSPECTOR REQUIREMENTS (FULL TIME ONSITE - FY 81)
Regional Onsite j
Inspectors Inspectors I
Pre-CP 10 0
Construction 0
42 Pre-Ops 0
20 Startup 0
11 Operations 0
60 Inspection Support Coordination 30 0
Tech Support 177 0
Safeguards 38 0
TOTALS 255 133 388 Alternative 4: Continuous Onsite Inspectors Inspector requirements for this alternative are also based upon the number of sites and the phase of each shown in Table A-2.
Regional inspectors would continue to conduct all Pre-CP inspections. For reactors under construction or in preoperational test one shift coverage is considered to suffice, since these are basically single shift operations.
For reactors in these phases, the onsite inspectors would perform the same duties as their alternative 3 counterparts.
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For reactors in startup testing or in operation, three shifts of coverage are required.
Onsite inspectors at these facilities would accomplish the complete reactor inspection program.
Five inspectors would be required to provide three-shift coverage.
This is based on 21 shifts per inspector and needed overhead (leave, sickness, etc.) per week, 5 shifts A supervisor is required for the five inspectors.
For startup and operations phases, this alternative does not require inspection support from the Regions, because the six inspectors assigned to each site could be chosen to include all the required expertise. Also, if one of the 'five inspectors is a health physicist and one is a safe-guards inspector, these two inspectors could accomplish the full reactor health physics and safeguards inspections with no regional support.
Site coordinators are still required in the Regions at the rate of one coordi-nator for four sites.
Table A-9 sumarizes the inspector manpower requirements for this option.
TABLE A-9 INSPECTOR REQUIREMENTS - FY 81 (Continuous Onsite) l Regional Onsite Inspectors Inspectors Pre-Cp 10 0
Const 0
42 Pre-Ops 0
20 Startup 0
66 Operations 0
360 Coordination 30 0
Tech Support 77 Safeguards 10 l
TOTALS 127.
488 615
- H.P. and Safeguards inspectors included in startup and operations onsite teams.
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A-11 Alternative 5: Continuous in Control Room As a minimum, five inspectors are required to provide control room coverage
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for 21 shifts per week.
This estimate is conservatively low because it assumes one inspector can stand an eight hour shift.
While this may be true, experience indicates that a four hour shift is more reasonable and that nine inspectors are required.
considers only 5 control room inspectors per control room.To remain conse In FY 81 there will be 108 operating reactors with 11 of these in startup testing.
A control room inspector is assumed to be stationed at each reactor even though a control room may be shared by more than one reactor, because of the current trend toward isolating reactor consoles.
for the 97 operating reactors requires 485 inspectors and similarContinuous cover coverage for the 11 reactors in startup requires 55 inspectors.
Since this option does not provide a means of conducting the rautine inspec-tion program, but rather is designed to augment that program, the control room inspector could be added to the baseline current program or to any of the alternatives.
i In practice, however, it is not reasonable to consider adding this option to any alternative other than 3 because of resource implications.
Table A-10 shows inspector requirements for alternative 3 (Table A-7) plus control room inspectors.
TABLE A-10 INSPECTOR REQUIREMENTS - FY 81 ONSITE CONTROL ROOM Regional Onsite Inspectocs Inspectors Pre-Cp
, 10 0
Const 0
42 Pre-Ops 0
20 Startup 0
11 Operations 0
60 Control. Room 1
540 Inspection Support Coordination 30 0
Tech Support 177 0
Safeguards 38 0
TOTALS 255 673 928
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A-12 i
Special Inspection Teams Appraisal inspections must be performed frequently enough to serve as a credible incentive.
For resource estimation, one inspection per site per year for each reactor phase; construction, preoperatifnal or startup test, C or operation, represented at the site is assumed.
ence suggest that a team may spend one week preparing for an inspection, one week conducting the inspection and two weeks preparing reports and Inspectors presently use approximately 25% of follow-up documentation.
available time for leave, sickness, training etc., leaving 39 man-weeks /
Each team, then, will be able to accomplish year for inspection workload.
Table A-2 showed the ten performance appraisal inspections per year.With one inspection per site and 10 number of sites per phase in FY 81.
annual inspection per team, Table A-11 shows the number of, teams required.
TABLE A-11 APPRAISAL TEAMS - FY 81 i
Const 6
Pre-Ops 3
Startup 1
Operations 7
For construction sites, The compcsition of the teams will vary by phase.
the team will consist of a leader, a quality assurance specialist, and three (3) technical specialists.
For operations, a leader, an operations For pre-specialist and three (3) technical specialists are required.
operations and startup testing a leader and two testing specialist will be required. Combining Table A-11 with these teams sizes yields Table A-12.
TABLE A-12 PERSONNEL REQUIREMENTS - FY 81 APPRAISAL TEAMS 30 Const 9
Pre-Ops 3
Startup
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A-13 O
Confirmatory measurements are to be conducted by one IE inspector as a leader and two contractor personnel who furnish special expertise, equipment and/orsanalysis.
in length, therefore, each inspection represents 40 man-hours inspector resources.
It is reasonable to anticipate that there would be a requirement for use of this capability in conjunction with the annual appraisal inspection.
Assuming further that the Regions would call upon this capability one additional time per year for each site yields two confirmatory measurement inspections per site per year.
These measurements would apply only to constr opportunities for independent observation to preclude tha need for these measurements.
conduct " hands on" activities during active licensee te on Table A-2, there are 133 construction and operations sites to b Based for a total of 266 inspections per year.
6 Table A-13 summarizes th2 sites, inspections and IE inspector-hours required.
TABLE A-13 CONFIRMATORY MEASUREMENT - FY 81 PERSONNEL R Inspections Total IE Insp-Hours Total Insp-Houi per year Sites Insp per Insp Required Onsitj Construction 2
62 124 40 4960 Operations 1
_ 71 142 40 5760 TOTALS 4
133 266 80 10720 Assuming a confirmatory measurement inspector can spend 500 ons per year brings the total IE requirement to 20 inspectors.
of licensee supplied information and inspection resul that one man-month of performance analysis support is needed for eac It is assumed reactor in startup or operations each year.
reactors in FY 81, this amounts to 108 man-months of analysis.For the further. assumed that one-half man-month per year is required for sit It is pre-ops or under construction.
For the 62 sites in FY 81,- 31 man-months are required.
formance analysts are required.With 9 man-months / year of productive In addition, these performance evaluations O
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A-14 will require the support of one statistician, one reliability analyst and O
five data system support personnel (one per Region) for a total of 23 personnel.
The special inspections require performance appraisal inspectors (77), confirmatory measurement inspectors (20) and performance evaluation analysts (23) for a total of 120 people.
Thus, a new division office will be required. This will involve a Division Director, Deputy, three Branch' Chiefs and three Section Chiefs in each branch (14 supervisors). Each supervisor will require a secretary and each section will require an additional clerk typist (23 administrative).
Contractor personnel (2 per team) will provide one week onsite time and one week for preparation and wrap-up.
Thus,1064 man-weeks of contractor direct labor is required to accomplish the 266 inspections per year.
Assuming 45 man-weeks of direct labor per man-year results in 24 man-years of contractor effort required each year.
At $80,000 per man-year, $1.9 million of contractor effort is required.
l Support Resources Table A-14 summarizes additional IE support personnel required for each alternative.
TABLE A-14 FY 81 SUPPORT PERSONNEL ADDITIONS Alternative 1
2 3
4 5
Training 10 13 32 58 Region Admin 1
10 (44)
(9)
Onsite Admin 71 71 HQ Admin 4
4 4
TOTALS 11 27 63 124
( ) indicate negative numbers e
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A-15 The following paragraphs discuss the derivation of these numbers.
Training. The additional inspectors present a need for augmented training resources.
Currently, each instructor accomplishes 52 inspector manweeks of training.
Assuming this yield can be main-tained in the future, the additional inspectors (Table 1 Section III) times three weeks of annual training creates a need for 6, 8, 21, 39 additional instructors for alternatives 2, 3, 4 and 5 respec-tively. As instructors are increased in this manner there is a need for additional supervisors and administrative support. The training additions are summarized in Table A-15.
TABLE A-15 ADDITIONAL TRAINING PROGRAM NEEDS Alternatives 1
2 3
4 5
I Instructors 6
8 21 39 Supervisors 2
2 4
6 Administrative 2
3 7
13 TOTALS 10 13 32 58 Regional Administrative Suoport.
In FY 77, there are 369 ir.spectors for each administrative support position.
Additional administrative personnel required for each alternative are estimated by dividing the additional inspectors (from Table 1 Section III) by this ratio.
This results in one additional person for alternative 2, ten for alternative 3, 44 less for alternative 4, and nine fewer for alternative 5.
Onsite Administrative Support. There will be 133 inspectors at 117 distinct sites in FY 81 for alternative 3.
They will require clerical assistance to handle mail, filing and typing.
Ten hours of this assistance per week will be provided on a temporary hire basis.
For 133 inspectors, approximately 34 temporary positions per year will be needed.
For alternatives 4 and 5 one full time admin person is located at each of the 71 sites that are staffed for continuous coverage.
HQ Administrative Support.
No additional headquarters personnel are required for alternatives 1 and 2.
For alternatives 3, 4 and 5, four administrative support personnel are required: one to coordinate logis-tics arrangements, one to handle the coordination with GSA that will be required and two clerk typists.
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Ar16 Costs. Total dollar requirements are constructed as shown in Table A-16.
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TABLE A-16 FY 81 TOTAL COSTS ($ MILLIONS)
Alternatives 1
2 3
4 5
Salary & Benefits 31.1 36.0 37.6 46.3 58.6 Travel 3.8 4.6 4.8 5.9 7.4 Admin Support 2.35 2.65 4.65 5.75 4.65 Contract Support 5.1 7.3 7.6 8.2 9.1
.75
.75
.75
.75
.75 j
Equipment TOTALS 43.1 51.3 55.4 66.9 80.5 Salary and benefits expenses are estimated based on an average salary of
$32,840 per annum (FY 81 FYP $31.1 M divided by 947 employees).
Travel expenses use the FY 81 FYP estimates as a base and adds $4,150 per new employee. Administrative support costs use the FY 81 current program base and add the dollars needed for onsite facilities and temporary administrative personnel. Trailers will be furnished with office equip-ment for the inspector (s) and a clerk typist.
Separate telephone lines, copy machine, telecopy machine and phone answering device will be furnished.
Assuming a trailer lease ($2700), utility and phone cost
($6600) and equipment / supplier ($5000), the annual facility support cost is $14,300.
For 117 sites, this amounts to about $1.6 M annually.
Contract support is estimated based on the FY 81 current program base with additional training courses, confirmatory measurements and program evaluation contracts.
It should be noted that the cost of training course.s may be underestimated for alternative 5 if control room inspectors require training substantially beyond that normally envisioned for inspectors.
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APPENDIX B INSPECTOR ONSITE PRESENCE Because of increased opportunity for independently verifying licensee activities and increasing the knowledge base for technical decisions, the inspection alternatives examined include various ways of increasing i
onsite time.
In the current program, inspectors typically spend 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> / year onsite. This, multiplied by the number of regional inspectors required for each alternative gives the total annual onsite hours expected from regional inspectors.
placing inspectors near clusters of facilities would reduce their travel time by at least or.a-half and allow them to spend this time onsite.
The total onsite time available to each site vicinity inspector then would be 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> annually. The number of
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inspectors (13) multiplied by the time available provides their annual onsite time.
More onsite time enhances the interaction between the NRC inspector and the facility staff. Although all working time may not be spent in direct inspection of licensee operations, the presence of an inspector on a site provides the opportunity for contact between the NRC and licensee personnel and encourages awareness of regulatory requirements on the part of licensee management.
Therefore, any time an onsite inspector is actually present at the site is considered to be onsite time. Approxi-mately 25% of an inspector's annual available time is spent on leave, in training or otherwise unavailable. The remaining hours,1560 per year per onsite inspector, multiplied by the number of inspectors gives the total onsite time.
This method is used for determining the onsite time provided by all onsite inspectors in alternative 3, since full time coverage is provided during all reactor phases; and for onsite inspectors covering the construction and pre-ops phases in alternative 4, because their coverage is essentially the same as that in alternative 3.
Alternative 4 provides continuous coverage during startup and operations.
To determine the onsite hours provided by NRC inspectors, the number of sites covered (71) is multiplied by 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> /per day coverage for 365 days per year.
Onsite hours provided by control room inspectors in alternative 5 is also determined by multiplying the number of control rooms (108) by the total number of hours per year.
Perform'nce appraisal inspectors conduct 10 inspections per year for 40 a
onsite hours per inspection. Therefore, the annual onsite hours provided by these inspectors results from multiplying the number of inspectors (77)
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by 400 onsite hours each.
Confirmatory measurement inspectors (20) ag assumed to provide as many onsite hours per year as Regional inspectog 500 each. Table II-1 summarizes the total onsite hours provided by eaa type of inspector. The number of inspectors of each type is shown in Appendix A.
TABLE II-1 ANNUAL ONSITE HOURS BY TYPES OF INSPECTOR (FY 81) 1 2
3 4
Current Site Full-Time Continuous Program Vicinity Onsite Onsite Regional Inspectors 175,000 171,000 127,500 63,500 I
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Site Vicinity Inspectors 7,800 Onsite Inspectors 207,480 96,720 Continuous,Startup/ Operations 621,960 Continuous, Control Room Performance Appraisal 30,800 30,800 30,800 Confirmatory Measurement 10,000 10,000 10,000 TOTALS 175,000 219,600 375,780 822,980
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..i' APPENDIX C PHASED MANp0WER - ALTERNATIVE 3 It is estimated that 18 sites are located close enough to the Regional Offices to provide an onsite inspector without a physical move of the inspector's home.
It is further estimated that 17 current inspectors would be amenable to a move to an onsite location in FY 78 Thus, 35 (of 98) sites could be covered by full-time onsite inspectors in FY 78.
Assuming two (5%) of these inspectors are lost to attrition in FY 79 and that 13 more move to the sites, 46 sites (of 103) could be covered in FY 79.
In FY 80, the first group of recruits will become eligible for on' site assignment.
Assuming two onsite inspectors are again lost to attrition, moving 67 of these two-year inspectors will provide full time onsite coverage at each of the 111 sites.
In FY 81, l
27 moves will be required to replace attrition and bring the onsite inspector force to the 133 inspectors needed for 117 sites. Onsite I
staffing for future years then becomes a matter of replacing attrition and satisfying new requirements.
At the end of FY 77, there will be approximately 153 reactor operations and construction inspectors (excluding non-power reactor inspectors and health physics inspectors) on board in the Regions.
It is estimated that 15% of this workforce will be lost to attrition each year (except those assigned onsite). This attrition, coupled with the placement of 35 of those inspectors onsite in FY 78 and 13 more in FY 79, causes significant reduction in the experienced workforce in the Regions which must provide technical support and coordineie for onsite inspectors.
A number of inspectors must be recruited O h 78 to supplement those remaining from the current workforce and br% the regional support inspector strength back up to the level required for full implementation in FY 81.
In addition to phasing in the inspectors required for onsite and regional duty, the training organization must be staffed to cope with an increased training workload; the special inspection teams must be built and appropriate Headquarters and Regional administrative support must be added.
To attain implementation by FY 81, the training staff must be augmented immediately (13 positions, Appendix A). Also the ten administrative support positions in the Regions and the four Head-quarters positions identified in Appendix A must be added in FY 78 to handle the influx of new employees and the administrative details e
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associated with establishing the site offices.
Recruitment dEu tors, analysts, supervisory and administrative support persone the special inspection teams is phased gradually throughout M FY 81 time frame.
The final consideration in determining phased manpower requinum is attrition.
It is estimated that 15% of the new recruits wM lost to attrition in each year so that initial recruitment ise to accommodate.these losses.
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