ML19323A288
| ML19323A288 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1980 |
| From: | Greher E, Slider J, Thompson S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), TEKNEKRON, INC. |
| To: | |
| Shared Package | |
| ML19323A239 | List: |
| References | |
| NUDOCS 8004180197 | |
| Download: ML19323A288 (61) | |
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RE?CRT TO C0ftGRESS Ctt 7pg RESIDENT ins?ECTOR PRCGRAM 800.4180197
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RE?0RT 70 CCNGRESS ON THE RESIDE'lT I!1SPECTCR FRCGRAM i
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elliott Greher Office of Inspection and Enforcement Nuclear Regulatcry Ccanissicn i
4 Sharon R. Thomoson James E. Slider Teknekron Research, Inc.
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Manuscript Completed: March 1980 Date Published:
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800.4180197 L
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SU W.ARY l
The :2C has learned a great deal during the first one and one half years of ne resident inscector crogram.
The potential benefits of. lccating inscectors at reactor sites aopear to be as strong as, if slign:ly different frem, those criginally conceived.
We have also fcund that managing a dispersed inspection force so that benefits are fully realized requires close coordination and attentien to planning.
The advantages originally envisioned for resident inspection have already been realized. NRC now depends less on records review because tne resident inspector is ansite, directly observing critical and routine licensee activities.
The resident inspector, having ac:;uired a broader and deeper kncwledge through this direct observation, is the NRC expert on how this licensee operates, giving NRC one or more specifically knowledgeable authorities on the licensee who are quickly available when a question l
arises or an incident occurs.
Resident inspectors use their knowledge to direct their work activities to suit both their professional style and inspection program needs. Tney can devote time to safety issues because of their continual presence onsite, their flexible work schedule, and their broad-based training. Under an expanded and earlier manning schedule even more time will be devoted to directly observing licensee activities.
The resident inspector himself benefits in assuming a more responsible position, one which allows him to gain in-depth knowledge that he can more effectively use to inspect, and ultimately insure, the safety of licensee activities. He also spends less time in travel, thereby minimizing family separations.
Unforseen communications advantages have also developed.
Comunication between the licensee and NRC has improved, since licensees say they can discuss plant ~ technical problems ure readily with the resident, who can effectively discuss them with NRC.
The resident inspector clarifies regulations and technical specifications for the licensee.
Comunication between NRC offices has also improved.
Since the resident I
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inspect:r has a better understanding of the plant and licensee actions and clans, he can more effectively assist in the develecment cf the NRC cositicn as to what a licensee musc co 50 cer*ect a orcolem.
Thus, the resident ins e:::r is a vitsi ::mmunication link :: totn the Office Of Insoecticn and Enforcement and the Office of Nuclear Reactor Regulaticn.
Licensees are enthusiastic about resident inspecc:rs, althcugn they still are unwilling to state that the residents actually im rove safety.
Licensees generilly believe that :ublic a:cectance of the safety of nuclear ocwer may be ennanced due to the presence of resident insoectors.
Nor is the licensee's operation disrupted by the resident inspector:
he conducts his inspections without an escort, retrieves documents without assistance, and is able to c:ntact the aperceriate person for information.
CONGRESSIONAL CONCERNS In its request for this report, Congress stressed two concerns:
that the individual resident inspectors might not have the breadth of technical knowledge to oversee the construction and operation of a nuclear power plant, and that the frequent contact with licensee personnel might lead the resident inspector to lose his objectivity.
Breadth of Technical Knowledge: Each inspector does not possess qualified knowledge in all technical areas.
NRC's Inspection Program recognizes this:
e The resident inspector functions as the principal inspector for the site, conducting general inspections in a variety of areas.
Specialist inspectors from the Regional Office sucoort and supplement the resident's efforts.
e Senior resident insoectors must have the appropriate skills before assignment. Junior resident inspectors receive most of their training after assignment to a site. The training program keeps experienced inspectors current in their fields and prepares junior inspectors for their new assignments.
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O Possible Loss of Objectivity:
The resident insoection conceot originally authorizec olaced one insoector at a site.
This could lead to loss of c:jectivity and easures were adacted to minici:2 this cessibility:
selec mature, ex:eriarted ins:ect:rs; limit :he tour ;f duty 1 a si:a; 5 reng:ne :ne ::ce of c ncuct; and contact regicnal sucervisers frecuently.
The expanced resident inspecter crcgram now recuires a minimum of two resi~ cents at all coerating sitas, and the
- resanca of one er acre associates is tae cest method for reducing the pctenti al for 10:: Of ;bject!vity.
Nevertheless, NRC expects to devote considerable at:antion to datecting any loss of obj.ectivity.
Regional sucervisors are sensitive to this issue and our licensee performance acoraisal inscections specifically review this possibility. The NRC will rectify these situations as they occur.
IMPLEMENTATION The fiscal year 1979 staffing goal was 49 inspectors at resident sites.
This goal was not met--only 40 inspectors were onsite by September 30, 1979, because of logistical and administrative problems in starting the program in fiscal year 1978 and diversion of manoower to the Three Mile Island response.
Many of these problems have been resolved and NRC is meeting the much more demanding goal for the end of fiscal year 1980:
PLANNED STAFFING ACTUAL STAFFING (at end of FY1980)
(as of 11/30/79)
Selected Onsite For Location Sites Insoectors Insoectors Transfer Operating Reactors 63 135 43 53 Construction Reactors 20 20 12 7
Fuel Facilities 3
2*
2*
O TOTAL 86 157 57 60 One inspector covers two neighboring sites, iii
The original goals of the resident insoector program were to establish an NRC onsita presence, to increase onsite inscection time, and to emanasize direct verificaticn of licensee activities. NRC cresence at reacter sites is a reality and in effective regulatory :cl.
Se goal fer re-e ensdte time has also been acc molisned:
casiden: ins:ec:ces :evota in average af 5a cercent of their time to inscecticn Ocmoared to accut 25 percent for regicn-based inspectors.
Insoection time for residents is excected to again increase significantly as the exoanded pregram is imolementac.
Inscection procedures are new being reoriented to meet the goal of more direct verificatien. The second and third resident ins:ectcrs at each sita will fccus almost exclusively en indecendently Observing and verifying licensee actions, and senior resident inspectors will continue to devote most of their efforts to direct verification.
Resident inspectors can respond quickly to incidents cccurring onsite'or nearby. They provide an important ccmunications link to the NRC, relaying information quickly and, because of their more comolete facility knowledge, accurately and in detail.
The difficulties encountered in implementing the resident inspector program stem mainly from the speed with which inspectors are being placed onsite.
Staffing the resident inspector program has depleted the pool of experienced NRC inspectors, and there is some concern that the regional inspection,
- response, and supervisory capability may be temporarily affected.
Scoping the full range of implementation needs is difficult.
Rapid expansion of the program and changes in its emphasis require that implementation tasks be redefined and new tasks added on short notice.
Establishing and manning many separate resident offices is a substantial administrative burden.
Lack of.onsite support staff has placed some of this burden on the resident inspectors, the administrative and supervisory load has been borne by an insufficiently expanded regional staff.
Relocation is a but den on the resident inspectors, since reimbursement for selling / buying a acme and for moving
- expenses have too often proved iv L_
insufficient to cover the actual cost of' relocation.
Increased cc.T...ning excem e is not reimoursaole. Moreover, the resident inspector may be less
- 11ing t: ac:eet a premetien bef:re the anc of his resident t ur,-
ince t!'e financial inc ametional c st f 1 ::ssith Isc:n; Palccatt;n in a short th* may be ::o great.
'ditn pecter planning anc coordination, many of these current difficulties shoulc be eliminatac baf:re the pregram is fully implementad.
The Executive Director for Ooerations' soecial task ferce is reviewing potential sclutiens, including legislative actions; the l
Office of Inspection and Enforcement is considering changes in its headquarters organization to more effectively implement the resident inspector program.
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TABLE OF CONTENTS Pace ICMMARY i
1.
INTRODUCTICN 1
2.
HISTCRICAL BACK3RCUND OF THE RESIDENT INSPECTOR PRCGRAM 3
3.
PLANS AND ACCOMPLISHMENTS 7
3.1 The Revised Insoection Program 7
3.2 Acccmolishments of the Resident Inspector Prgram 12 3.3 Acccmolishments in Performance Appraisal 18 3.4 Accomolishments in Direct Verification 19 3.5 Accomplishments in Training and Career Development 20 4.
ADVANTAGES OF THE RESIDENT INSPECTOR PROGRAM 22 4.1 Advantages to NRC 22 4.2 Advantages to the Resident Inspectors 25 4.3 Advantages to Licensees 25 5.
DISADVANTAGES OF THE RESIDENT INSPECTOR PROGRAM 29 5.1 Disadvantages to NRC 29 5.2 Disadvantages to the Resident Inspectors 33 5.3 Disadvantages to Licensees 35 6.
CONCLUSION 37 7.
REFERENCES 39 APPENDIX :
PERCEPTIONS OF THE RESIDENT INSPECTOR PROGRAM A-1 A.1 Licensees' Perceptions of the Resident Inspector Program A-1 A.2 NRC Perceptions of the Resident Inspector Program A-7
1.
INTRODUCTION In the House of Recresentatives Recert acccmpanying tne 1RC Au:hcrintien 3ill fer fiscal year 1979,( s the Ccmittee on Intarstate and Foreign Ccmmerce remarked:
Although the ccmittee acoroved witnout change the NRC request for the Off_ ice of Inspection and Enforcement, it continues..to have reservations abcut the orcpcsed Resicent Inscector Progrgm.
The ccmmittee believes that the placement of an NRC employ,ee at the site of an coerating reacter or one under construction mignt lead to a familiarity with the operator or contractor which impairs the insoector's objectivity. This observation is, in no way, meant to raise cuestions as to the character or integrity of any inscector.
Resident insoectors will have more frequent contact with the coerator or contractor than they have with other NRC emolayees, and the likelihcod of less than total objectivity must be viewed as a natural cutgrowth of this phenomenon.
Every effort must be exerted to guard against this possibility. Additionally, the ccmittee questions the caoacity of any one individual to possess the requisite knowledge in multiple technical areas to effectively oversee the construction and operation of an entire nuclear power plant.
Given these reservations, the ccmmittee believes the Commission should vigorously oversee the implementation of the resident inspector program and submit an evaluation to Congress by January 1, 1980, of its progress and problems, i
This report, on the progren and problems of implementing the rasident inspector program, has been prepared in response to that request.
In
- addition, we have addressed Congressional concerns abcut loss of objectivity and breadth of knowledge, and discussed the advantages and disadvantages that have become apparent in the firtt year of implemen-tation. However, this is not a full-scale evaluacion of the effectiveness cf the program; that evaluation is being conductad by Teknekron Research, Inc., under Contract NRC-05-79-254. An evaluation of the fiscal year 1979 experience is to be ccmpleted by July of 1980; the fiscal year 1980 experience is to be evaluated by March 1981.
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- n :ne time since Cengres: 1sksc fcr n's ee:cr: On :ne imolamentaticn cf
- na esicen: ins:ector :regram, reac:icn :: :ne Three Mile Islanc ic icen.
has ex anded the r0 gram's scc:e and form.
To place the current expanded orogram in context, Section 2 cf Inis recort gives a brief nistorical sketen of resident inscector program develcoments uo : the cresent. Since resident inspection is part of a unified Revised Inspection Program, Secticn 3 sets ce: tne plans and acccmolishments of ee.ch cregram comconent, thcugn the resident insoector crogram is emchasized.
Sections 4 and 5 describe, respectively, cur preliminary assessment of t1e advantages and disadvantages of the resident insoector program. There has been a full year of experience at 12 sites, and more than 23.5 man-years of experience with the resident inspector program were accumulated through the end of fiscal year 1979.
Thus some advantages and disadvantages have already begun to appear, though it is too tarly in the program's history for definitive judgments to be made by NRC.
Much of the information in these two sections was gathered in interviews Tcknekenn Research conducted with NRC headquarters and regional
- staff, resident inspectors, and licensee personnel.
Congressional concerns--loss of objectivity and adequate breadth of any resident inspector's technical knowledge--are addressed where appropriate in Sections 3, 4, and 5.
Section 6 briefly summarizes the major points relating to those concerns as well as to the implementation of the program and its problems and benefits.
The Appendix presents the perceptions of the resident inspector program gathered in the interviews conducted by Teknekron Research.
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2.
HISTCRICAL BACXGROUND CF THE RESIDENT INSPECTOR PROGRAM ne idea of lccating insoecters at regulated sites is no: new to the
?luclear Regull:Ory C0mnissien (NRC).
In early 1974, tne NRC' precosec 1 c nceot of residen insoection in wnich an inspector would be assigned close to a cluster of reactor sites rather.than to a Regional Office.
A trial program based on this idea was tested at two locations, beginning in mid-1974 and ending in late 1976.
Evaluation (2) of the trial program results showed that:
e Onsite inspection time increased.
a Inspector knowledge of the plant increased.
e NRC awareness of plant status and problems improved.
These benefits suggested that resident inspection could use inspector time more efficiently, allow more direct observation of activities, enable NRC to focus more precisely on problems, and permit those problems to be more quickly resolved.
The dollar costs of increased administration and relocation appeared likely to be offset by increased inspection efficiency, and the trial program produced no clear evidence of loss of objectivity.
NRC realized that mature and experienced inspectors were fundamental to maximizing the benefits of the program and minimizing the potential for loss of objectivity.
Based on the trial program experience, NRC analyzed four alternative approaches to resident inspection.( ) These alternatives were:
1.
Basing an inspector near a cluster of sites (the trial program aooroach).
2.
Basing at least one inspector full time at each site with a reactor under construction or in operation.
- Then, the Atomic Energy Ccmission.
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Providing 24-hour inscecticn at sites with reactors in startuo er oceration; sites with reactors under construction er in crecaeraticnal testing receive the full-time coverage
- ssericed in Alternative 2.
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Fr viding It-ncur c:ntrol r:cm meni:Oring in addi:icn to tne insoection provided in Alternative 2.
In eacn alternative, the residen: insoect:r was to receive technical support frcm inspectors working cut of the Regional Offices and from inspection teamt soecializing in indeoendent measurement and in-death performance acoraisal.
Using the existing inspection program as a baseline, NRC evaluated each alternative agains: qualitative criteria associated with crogram perfor-mance (how the program might affect the inspectors' competence, usefulness, flexibility, and objectivity, and how it might motivate licensees) and against the quantitative factors of manpower needs, dollar costs, and effectiveness and efficiency as excressed in onsite time. Based on this evaluation, NRC chose to implement the second, " full-time onsite,"
l alternative:
it would more than double total onsite
- time, would substantially increase the amount of direct verification, and would provide "high utility," by maximizing the inspectors' opportunity to focus on activities meaningful to safety, while costing only 30 percent more than the baseline program.
Alternatives 3 and 4 further increased onsite time but cost substantially more without providing a corresponding increase in inspector utility. NRC recognized that Alternative 2 carried the greatest risk of loss of objectivity, due to assignment of (usually) a single inspector to each site and to the inspector's daily contact with the licensee, but felt this potential risk could be limited by proper choice of personnel; contact with Regional Office inspectors and supervisors; and by limited tours of duty.
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In April 1977, the President asked NRC to implement a program that would place resident inspectors at power reactor and other nuclear sites.
In June of 1977, the Ccmissioners aoproved a " Revised Insoection Program"
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l which included full-time onsite resident inspection as one component. The a
Other three ::mtenents are a :erf:rmance sporaisal group that conducts in-de:th evaluati0ns of licensees' management systems and evaluates the
'm: lamentation f :ne entire ins ection Or: gram; increased incependent serifica:icn efforts f botn cirec
- cservnien of licensees' activities Inc
- cf' mat:ry me2:urran::' by NRC; and a trea:er training ano career develc: men
- r: gram.
a tually, there is liso a fifth, continuing c
c mocnent:
the technical sucocrt and the saecialized insoections nat c:ntinue : be :revided by the five Regicnal Cffices.
Tnus, the resicent ins;:ec:cr :rogram is cart of a considered and broad-based approacn to ennancing :ne efficiency and effectiveness of NRC ins::ection. Each of the elements of the Revised Inspection Program is discussed in Section 3 of this report, thougn th'e resident inspector orogram receives the most
- emchasis, i
After the Three Mile Island accident, NRC was urged to markedly increase its insoection at all sites. In July of 1979, the Office of Inspection and Enforcement recomended stationing a
full-time insoector at each precperational and operating nuclear power unit, in addition to a site resident inspector. These additional resident: were to focus primarily on direct ver'ification of licensee activities, and thus augment NRC's knowledge and confidence about the safety-related performance of licensees.
In late July 1979, the Comissioners aaproved an expanded program, and recruitment began in order to provide a minimum of two resident inspectors at most sites.
One-unit sites and two-unit sites will have a senior resident inspector and an additional resident inspector; three-unit sites I
will have a senior and two additional resident inspectors.
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construction sites to be staffed with resident inspectors has also been increased to provide adequate coverage of quality assurance programs at I
plants in the earlier stages of construction, including those where specific problems have been identified.
The fiscal year 1980 Congressional Appropriation for NRC (May 1979) provided funding for an additional 146 positions to implement the expanded resident inspector program.
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9 It must be emchasize that resident insoection does not represent a change in NRC's basic philosopny:
that the licensee is resconsible for the safe construction and coeration of a nuclear ocwer clant.
'1RC's role is to assure that this es:Orsibility is discharged.
7,e resicent inscector program is cesignec :c make ilRC's -cie mer:
effective.
The resident inspector, as NRC's ensite " eyes and ears,"
should:
i Increase NRC's knowledge of conditions at tne facility, thereby firming the basis for regulatory action Directly observe licensee actions, in addition to examining e
records of those actions Improve NRC's ability to respond quickly and effectively to e
plant problems through his greater knowledge of the facility and the workings of its staff The presence of the resident inspector cannot, nor should it, substitute for the licensee's basic responsibility to safety, but it should help NRC assure that this responsibility is being met.
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3.
PtANS AND ACCCMPt.ISHMENTS
'ihile 15 sitas+ 1:a ine residen; in: cec: Ort. 12 :i:ss" co not, those sitas not staffed with resicents are sucjec: exclusively to 1RC's regien-bas ed inspecticn ;regram, in which inspec: Ors are located in Regicnal Offices and periedically travel to the sites.
Each coerating reactor licensee typically receives acout two insoections of two to five days duration each month; reactors under construction are inspected two to four times per month decending on the stage of construc' tion, and fuel facilities receive at least ene inspection per month.
Regional inspectors are eitner principal inspectors er technical specialists.
Principal inspectors are responsible for conducting certain insoections, monitoring insoection status and coordinating insoection effort at a site to assure that all necessary inspection requirsents are fulfilled, and following up on outstanding items and enforcement actions.
Technical specialists are experienced in one or more areas such as health physics, welding, physical security, or nondestructive examination.
They inspect licensee activities in those specific areas, ccmplementing the broad-based insoections conducted by the principal inspectors.
Region-based inspectors examine a sample of technical procedures, management controls, and licensee records; directly observe a limited number of licensee activities; and make confirmatory independent measurements, particularly in radiological protection.
3.1 THE REVISED INSPECTION PROGRAM The Revised Inspectic. Program alters the region-based pattern of inspection to provide n~ c onsite time and more direct verification of As of Novemoer 30, 1979, resident inspectors were assigned to 31 sites with reactors in operation or in preoperational testing, 11 sites with reactors under construction, and 3 fuel facility sites.
- As of November 30, 1979, resident inspectors were not assigned to 33 sites with reactors in coeration or in precoerational testing and 9 sites with reactors under construction.
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licensee activities.
A brief descristien of each program ccmacnen: will help to place the actual acccmplishments in each area, as discussed later, in oerscective.
The Resident Inscector Prcgr'a The senior resident inspector functicns as the princioal inspector for tne site to wnich he-is assigned, conducting general inscections in a variety of areas.
Specialists frem the Regional Office continue to conduct in-depth technical inspections and provide other suoport the resident inspector may need. This dual acoroach recognizes that no one individual is sufficiently qualified in all technical areas. Technical succort by the Regional Office is essential to a comorehensive inspection program.
Resident inspectors scend essentially all their working time onsite.* This increased time provides greater cpportunity to cbserve and measure licensee activities directly, thus improving confidence in the accuracy of licensee work and records. The resident inspector can respond to incidents more quickly because no time is isst in travel frem the Regional Office.
He also has more coportunity to beccme familiar with the details of the plant and its operation, which is expected to give NRC a better technical basis on which to take any required regulatory action.
Perfomance Aooraisal Team Performance Appraisal Teams of highly qualified, experienced inspectors conduct inspections that have three purposes:
- 1) evaluating the performance of NRC licensees frem a national perspective, 2) evaluating the effectiveness of the NRC inspection program, and 3) evaluating the objectivity of NRC inspectors.
" Not all onsite time is spent in inspection.
See Section 3.2.
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l The Performance Accraisal Team reports to IE Heacouarters, not to any Regional Office.
The team inscects f acilities in all regions, anc tnis "naticnal pers;ective" cn li:ansee perf rmance :: alements :ne ini:rmatica l
- c ained thr:ugn region-basec ins:ecticn and the sita-based casi en inscector.
The national perscective gained by a single gr:uo concucting inscections in all NRC regicns can also provide informaticn on hcw consistently the regions are imolementing NRC's inspecticn or: gram.
The Performance Accraisal Team also evaluates inspection program effectiveness by acolying the tame ins:ection procedure as that used by the region ~-based inspectors but with a higner than required samoling rate; their results are c mpared with these obtained by t!.e regicnal inspectors kno use One specified lower rate.
Direct Verification Direct verificatien takes two forms - direct cbservation of licensee work, and independent measurements.
Both types of direct verification are intended to orovide first-hand assurance that the licensee has performed work properly.
Direct observation involves witnessing licensee activities in progress.
This "over the shoulder" observation is done by both resident and regional inspectors, though opportunities for direct observation were emphasized when structuring resident inspectors' activities.
Preoperational tests, power ascension tests, surveillance tests, and routine maintenance and operations can all be observed more frequently by resident inspectors and with greater convenience to both NRC and the licensees.
Independent measurements are " hands on" (as opposed to "over the shoulder")
insocctions, in which NRC inspectors personally perform certain activities.
Both direct observation and independent measurement permit the inspector to verify that the licensee is following written procedures and has measured and reported accurately. These inspection techniques can increase NRC's confidence in the technical performance of the licensee and 9
in :ne accuracy and comoleteness of licensee documentation.
Nonces-tructive examination, instrument calibration, and an exoanded radiological measurement arcgru are being evalua:sc for inclusien as incecencent measurements.
Scme measurements may be mest acccc:riately :erformec Oy site-cased inscectors,.vnile ::ners may be more effectively cerformed by regicnal perscnnel cr by scecializad teams coerating from a central locatien.
The additional rasident inscectors to be assigned to each site under the excanded resident program will focus primarily on direct verification.
This increased direct verification role emahasizes:
e On a regular basis, reviewing orocer positioning of valves and switches and proper equipment liaeup after maintenance Observing a sample of entire surteillance tests, starting e
by verifying that test instruments are properly calibrated, continuing through the test and return of equipment to
- service, conclucing with independent verification of formulae and ccmoensation factors e
Frequently verifying compliance with technical specifi-cations e
Observing whether safety-related maintenance is promptly scheduled, properly conducted, and quickly completed e
Verifying placement and removal of control jumpers e
Checking work-in-progress against precedures e
Witnessing portions of all safety-related startup and preoperational tests e
Conducting independent periodic radiolcgical surveys and measurements Continual Regional Support Specialist inspectors working from the Regional Offices complement the resident inspector's efforts, since NRC recognizes that no single person 10 l
is excert in all inscection areas. Basing tne soecialist insoectors in the regional offices is an efficient use of manoower, since one saecialist can insoect the same tacnnical area at several olants at a uniform level of detail.
The Regic.*ai Office is also the point or 'sucervision and administrative succort for tac resident inspectors.
Ncnccmpliances found by the residents are processed by the Regional Office, and the resident maintains frequent telechohe contact with his supervisor in addition to submitting periodic w*itten reocrts.
Insoector Training and Career Develcoment This cocoonent of the Revised Insoection Program supports the others by assuring that properly trained personnel are available to fill super-
- visory, resident,
- regional, and performance appraisal positions.
Assigning inscectors to nuclear facility sites for a " tour of duty" requires planned mobility and a greater assurance that inspector skills are matched to future inspection needs.
The inspector training program is designed to meet NRC needs.
Classroom instruction is supplemented by training sessions in a power reactor simulator and by programmed self-study and on-the-job training.
It is i
estimated that 18 to 24 months are required to train most new inspectors for duty as the senior resident inspector assigned to a site, even though they may have prior experience in the nuclear industry.
The other, more junior, residents require up to 12 months of on-the-job and classroom training, some of which occurs after assignment to a site. Currently, most junior resident inspectors are new hires (with previous nuclear experience in a utility or the Navy) who are assigned directly to sites and who receive their NRC training while assigned to that site.
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3.2 ACCCMPLISHMENTS CF THE RESIDENT INSPECTOR FRCGRAM Staffino i
The schecule for staffing the resident ins:ec::r program nas uncergene a number Of :hanges.
The " Original" schedule, as accroved 'ay tae Office of Management anc Sucget (CM3), was:
FY78 FY79 FY80 FY81 FY32 Resis'ent Inspectors 22 a9 75 93 98 Each figure includes two resident inspectors to be stationed at fuel facilities; the remainder were to be stationed at sites with one or more reactors in operation or at selected sites with reactors in the last three years of construction.
NRC obtained funding for the resident inspector program in July of 1978, and the first 22 resident inspectors were to have been onsite by September 30, 1978.
As of that date, eight residents were onsite.
By the end of December 1978, 18 resident inspectors were onsite:
2 at fuel facilities, 5 at construction sites, and 11 at operating sites. This delay in placing resident inspectors onsite was due to the difficulty of relocating people on short notice.
NRC's goal was to have 49 resident in pectors by the close of fiscal year 1979. As of September 30, 1979, 28 operating reactor residents, 10 construction reactor residents, and 2 fuel facility residents, for a total of 40 residents, were onsite.
The original plans for fiscal year 1980 called for 76 resident inspectors, an increase of 36 over the numcer actually onsite at the close of fiscal year 1979. Plans for fiscal year 1980 have now become more complex, due to the expansion of the program in the wake of the Three Mile Island accident.
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These clans new include acditional resident ins:ectors at each coerating si:e and scme acciticnal construction site coverage:
'::stien
?esicen Instec::rs
- erating Sitas Three '4ile Islanc 7
Other sites 128
- castruction Sites 20
.uil Facilities 2
TOTAL III As of the end of Novemoer 1979, 57 residents were onsite and 60 more residents had been selected.
It is no simple matter to find and place on site so many people in less than one year. Senior residents usually come frem the current ranks of regional inspectors.
The additional residents are expected to be less experienced person el of Icwer grade than senior residents, since the additional residents' job activities do not require the experience demanded of the senior residents.
Many of the additional residents are to be new hires with education or experience in nuclear, civil, mechanical, or electrical engineering disciplines, with a general knowledge of nuclear technology, and with particular knowledge in one or more areas of reactor operations.
Even with a reasonable plan, it is clear that staffing the expanded resident inspector program may be difficult.
Persons qualified to be senior residents cannot be removed precipitously from the Regional Offices without weakening the regional inspection program.
Placing newly hired persons at the sites as residents who focus exclusively on direct observation of defined activities has the advantage of relatively simple training, in comparison with the training and experience required of a senior resident inspector. But to produce a solid, viable, and productive inspection program, NRC must use only adequately trained and qualified inscectors.
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Use of Inscector's Time The way resident inscectors use tneir tine :iffers substantially fr:m the uay in wnien regional inscec:crs worx.
Mis::rically, -egional ::eraticns inscec: Ors have spen about 25 per:ent of :neir acrk time in ins:ection.'
Rougnly a fifth of tneir ensite time is scent in directly coserving acrk activities; the rest is scent reviewing dccuments. The regional inscector also spends about 10 percent of his work time in travel.
The remaining time is scent in. training, or in the Regional Office preparing for ucccming inscections by reviewing the licensee's inspection history and technical saecifications, evaluating inspection findings for oossible enforcement action, documenting inscections he has conducted, and reviewing licensee reports of events or malfunctions.
By contrast, the senior resident inspecters already onsite are averaging about 95 percent of their work time onsite, with 48.8 percent of their work time spent in routine inspecticn and another 4.6 percent in "nonrcutine" inspection (folicwing up on particular events, cccurrences, or licensee response to bulletins).
These figures are averages for all resident inspectors ** for the period October 1978-June 1979 and do not include overtime.
Less than 4 percent of the senior residents' time was spent in I
travel.
About 16 percent of their time was scent in documenting the results of inspections.
Another 19 percent was devoted to programmatic activities, particularly servicing requests frem other NRC offices:
the Office of Nuclear Reactor Regulation, Office of State Programs, and the Office of Public Affairs. Also included is the almost daily telephone call to their regional supervisors covering inspections in progress, events that occurred, and other items of interest.
Another activity, and one that takes substantial time, is reutine administration of the resident inspector's office. Much of this time would be better spent on inspection.
Some resident offices have been assigned Regional inspectors have been spending more than 25 percent of their time onsite since Three Mile Island.
- Operations, construction, and safeguards.
14
cart-time emolayees to handle the administrative work and to provide tyoing services. This acoroacn is now being usec in an increasing numcar f residen: cf' ices.
Table i summari:es Mcw regicn-basec and resicent ins:ect:r: ::end re 9 werk :Me.
e Table i AVERAGE TIME 3REACOWN ?CR REGIONAL AND RESIDEtiT INSPECTORS Regicnal Resident Inscectors Insoectors
% of '.4crk Time
% of '.icrk Time Routine Inspection 21.4 48.8 Investigaticn 7.4 4.6 Occumenting Inspecticns/
Enforcement Activities 25.5 16.0 Inspection / Management Support 12.5 19.2 Miscellaneous 22.6 7.6 Travel 10.5 3.8 TOTAL 100 100 NOTE:
No sick leave, vacation, or holidays are included.
Quick Response to Incidents Inspectors located at reactor sites can respond quickly to incidents cccurring onsite or nearby, since little travel is usually needed. The NRC Regional Offices and Headquarters can obtain promot and accurate information from the resident inspector.
For example:
15
s A resident insoector in Region I investigated a soill from a truck carrying materials that were susoected to be racio-active.
He surveyed the area and oremotly assured tne 1: cal authcrities that no c:ntamination existec.
A resicen insoect:r in Region III was called at 1cce :y the licensee wnen :ne reacter tri::ec lata at nignt.
Th e resicent returned prcmotly to the plant, assessac the situation, and was aole to inform NRC neaccuarters that no sericus problem existed and tnat the licensee had taken orcoer action.
NRC headcuarters and the Region III Office were able to pass promot and accurate information en to the press.,
A resident insoector in Region II was noti *ied at ncme by e
the licensee when a minor release, followed by a reactor shutdown, occurred early in tne morning.
The resident returned and notified NRC headquarters and the Regional Office.
Over the next few hours, he provided the basic information NRC needed to evaluate the situation.
Achieving an Integrated Inspection Program The written inspecticn procedures have gone through two revisions to accomodate the resident inspector concept, and further modifications will undoubtedly be needed as NRC gains more experience and as the orogram's technical emphasis charges.*
The initial revision came when the first residents were placed onsite in late fiscal year 1978.
At that point, one could make only an educated guess about the actual manhours available to the resident for inspecting and how those hours could be most productively used.
The regular "modularized" inspection program was retained essentially intact, but with the sampling rate for some modules increased.
Procedures covering health physics and physical security were recast to make them more amenable to performance by the resident inspectors, and direct observation activities were specifically increased in most areas. Some regions required that all
- Tecnnical emphasis is already changing in response to Three Mile Island and to increased storage of spent fuel, as it did in response to such previous events as pipe cracking, the Brown's Ferry fire, and fuel densification.
16
tne revised mcdules (called the "C" level crogram) ce comoleted solely by the resident inscector, but this proved to be extremely difficult.
In 20ditien, many easitant: felt : heir :ime wculd be bet:ar 3:en: in 3r:cing areas ney knew to be weak, cinting out Octential :r:ciams ant recuiring tna: licensees take action to orevent ncnc moliances frca cccurring, Inc in directly casarving licansee activities to an even grea:ar degree.
The program revision new underway reflects this exoerience.
New modules are being written for the additional residents, who will focus primarily on indeoendently cbserving and verifying licensee actions.
ihe emonasis of existing modules is being shifted to include more direct cbservation by all inspectors, not just the residents.
More hands-on testing by flRC (described later) is also being included.
The goal, after a year and a half of experience with the resident inspector program, is to produce an integrated program that combines regional and resident skills and advantages in a reasonable way.
Each Regional Office will divide the program modules between regional and resident inspectors to take advantage of the particular skills possessed by all the inspectors in that region.
NRC plans to have this revision ready for use early in 1980.
Management of the Resident Inspector Program In August 1979, a coordinator was appointed to define and monitor effort on the tasks that must be accomplished to implement and manage the resident inspector program.
An imolementation plan covering 11 priority tasks was approved by the Director of the Office of Inspection and Enforcement on October 18, 1979. The tasks are:
e Define Program Commitments and Goals e
Develop ' Routine" Inspection Programs e
Hire / Select and Assign Inspectors e
Transfer Inspectors to Outy Stations e
Administratively Support the Site Offices i
17
4 Train and Crient Ins;;ectors l
Recer: 'Acn:hly acccmcli sMent:
1 CeVelco Persennel and Crginizati0nal PCIICies a
Cecrdinate the ?regrim wi:n.1on-Pr gram Offices e
Deveico an Incident Resconse Precrim e
Prepare Policy /Information Papers The Office of Inscection and Inforcement is also considering altering the structure of its Headquarters office to ensure mere effective imolementaticn of the resident inspector pecgram.
Possible changes are being considered in the context of actions recomended by investigations of the Three Mile Island accident.
3.3 ACCOMPLISHMENTS IN PERFORMANCE APPRAISAL Ten performance appraisal positions were authorized for fiscal year 1973 and 15 for fiscal year 1979.
In f act, due to staffing the resident inspector oregram and to promotien to management positions, the Performance Appraisal Branch had only 10 members as of the end of fiscal year 1979, and several of these were detailed to the investigation of the Three Mile Island accident.
Despite these obstacles, the Performance Appraisal Branch:
Formulated detailed plans for conducting inspections of e
licensee management controls and of the effectiveness of NRC's inspection modules e
Conducted five management inspections (one in each NRC region) e Conducted five inspections (one in each NRC region) designed to test the effectiveness of the modular inspection program The " national perspective" that began to develop from tne five management inspections has revealed that licensees' structure and operation may vary i
i 18
more than NRC had realized.
The Branch also confirmed that the samoling rates used in the specific inspection precedure tested did in fact present in accura:a inc reliable picture of the licensees' ragulatory activities in :nat area.
The Perfcrmance Aporaisal 3 ranch has not yet attempted direct assessment of insoector cbjectivity, though prcgram implementation, including objectivity, is evaluated as part of each management inspection.
Eventually, the Performance Aporaisal Branch may play a more substantial role in this area.
3.4 ACCOMPt.ISHMENTS IN DIRECT VERIFICATION The region-based inspection program has always included direct verification. During construction, inspectors make spot checks of work in progress to assure that the licensee follcws his quality assurance program.
In the preoperational test and startup phases, insoectors witness and review the results of selected tests and analyze the test procedures. At an operating reactor, inspectors spend about 20 percent of their time directly observing or making measurements.
In addition, approximately 20 percent of an inspector's ensite time is "unprogrammed" to permit him to follow up on areas of interest or concern, and some inspectors use that time for additional direct observation.
The integrated inspection program mentioned in Section 3.2 builds on the existing program. First, the additional resident inspectors at each site are to devote nearly all their time to direct verification. Second, Sandia Laboratories has studied options for direct verificatienN during reactor construction and operation and has defined ways in which NRC can directly test the operability of systems and components important to safety.
The results of the Sandia study are being incorporated into the inspection program.
A third direct verification program will improve NRC's capability to independently assess radiological safety. This internally developed study 19
is evaluating sessible exoansion of tne types, frecuency, and the sample size of in-clant, environmental, and effluent measurements that are made periodically at coerating f acilities.
The stucy will also scecify :ne raciological meni:: ring or survey scui: men:
escac in eacn 3.agion al Office, resident office, anc at ether lccaticns to make tnesa measurements uncer both nor :ai and accident conditions.
3.5 ACCOMPLISHMENTS IN TRAINING AND CAREER DEVELCFME?C NRC's scecialized training group, a comoonent of the Office of Inspection and Enforcement, has grown from 7 instructcrs in the summer of 1979 to 14 as of the close of the calendar year.
Four more instructors are needed, and these positions should be filled shortly. The January 1979 sy11 acus of training courses offered 20 reactor operations courses.
Two more reactor simulator courses, covering transients and abnormal operating conditions, have been added, and the NRC has negotiated to extend its use of the Tennessee Valley Authority's simulators for three additional years.
Available simulator time has been expanded frem 13 to 29 weeks. A one-week course in cbservation techniques has been devised primarily for tne additional resident inspectors, and two advanced technology courses have been lengthened to three weeks each. NRC's Region II Office has prepared a training guide that covers the type and timing of on-the-job and classroom training a new resident inspector must have during his first year.
The guide is being considered for use by all five regions.
l As of October 1979, position descriptions and grade levels had been defined I
for use in assigning senior and additional resident inspectors to operating reactor sites.
Senior resident inspectors are established at the GG-13 or 14 grade. Other resident inspectors are graded, according to qualifications, as GG-11, 12, or 13.
Position descriptions for resident inspectors at reactor construction sites and fuel facilities are ccmparable to those of the reactor operations senior resident.
Under 20
- ntract to NP.C, General P.esearch Corpcration has d:Cumented altarnata
- areer c:ccetunities within the Office of Inscection and Enforcement.(5)
The :r:mo:icns available for a senior resident ins:ec:Or are tne same as T'esa Iv1111b'? : any scual y :ualifiec GG-14 ins:ec::r:
he can tec:=e a IL:irvi3 e in t9a iagicnll Office or join the headcuartars staff, cecencing upon :ne positi:ns open in eacn of these areas.
Inspectors of lower grade can risa througn the ranks.
A new ccm:utari:ed Personnel, Assignment, Qualifications and Training System (PAQTS) contains the training and exoerience history of all inspection eersonnel.
PAQTS will su:olement the regicnal supervisers' reconnendaticns for resident status or prcmotien by identifying additional training each person requires.
t G
21
4.
ADVANTAGES OF THE RESIDENT INSPECTOR PROGRAM The acvantages of tne resicent ins:sc: - Or0 gram accrue crimarj to tha NRC, but they also accrue to the resicant inscec: Ors and the licensees.
i Scme of the advantages benefit more tnan one of tnese grouos. Many of tne advantages to the NRC benefit the public througn the im:rovement of NRC':
ability to regulate effectively and with increased perceotion.
The information on advantages has been succorted by interviews performed by Teknekron Research, Inc., under an NRC Contract No. NRC-05-79-254 See the Appendix for Teknekron's discussion of the interview results.
4.1 ADVANTAGES TO NRC Increased Inspection Time In designing the resident inspector program, cne of the major goals was more onsite inspection. The objective was 56 percent of working time for the typical resident inspector.
As shown in Table 1 in Section 3.2, resident inspectors have, on the average, spent about 48.8 percent of their work time in routine inspection and another 4.6 percent in investigating particular problems, for a total of 53.4 percent.
In contrast, regional inspectors have historically spent about 25 percent of their work time in inspection, though this has increased since the Three Mile Island accident. Resident inspection has thus about doubled inspection time, and this increase may be even greater when more residents have clerical help and logistical problems, such as mail delivery, have been solved.
While time spent inspecting has increased, residents are also performing more inspections outside of normal working hours
("backshift" inspections).
Most regional inspections are scheduled for prime shift hours because that is when most inspectable activities take place.
The resident inspector, having the same access to the plant as an employee and 22
9 living closer to tne site, can more efficiently cover backsnift activities that are recuired to be inscected.
He also conducts more frecuent
surprise tackshift inscecticas cc soot-cneck routine coeration.
d 3 attar Scwledce of the Licansae An important aovantage is the resident inscector's carticular knowledge of c'
the olant and herit is being constructed, teuted, and coersted.
In almost all cases, this knowledge is both broader and deecer than that oossessed by region-based inspectors.
A major factor in develooing this enhanced knowledge is the increased amcunt of time the resident inscector spends in directly observing licensee activities.
Pecole's actions and ecuicment response, when seen firsthand, convey a different type of information than do the records of those actions and responses.
Tnis "real time,a more insightful knowledge about the licensee is expected to contribute to NRC's awareness of the safety of that licensee's coeration.
It is not easy to define necessary c.d sufficient conditioris that lead to safety, but good defense-in-depth
- design, cualified personnel, gcod maintenance, sound operating practices, and adherence to regulations all contribute.
The resident inspector's firsthand obser-1 vation of all of these factors should add a valuable dimension to NRC's regulatory scheme.
Tne resident inspector's knowledge of the plant also aids regional manage-ment.
Regional supervisors report that they use their inspection force more efficiently by following up on licensee weaknesses indicated by tlie resident inspector.
t Imoroved Response to Incidents j
A resideat inspector's more comolete knowledge of the facility allows him--and NRC--to respond to incidents occurring at the site in a more 23
informed way.
The resident insoector is likely to be more familiar with the nuances of the facility than is a region-based inspector, and hence he can olace an event in tne c:ntext of the clant's recent coerating history.
i Resicent inscec: Ors can also resconc cuickly to incicents cc:urring ensi a f
cr near:y, since sucstantial travel time is unnecessary.
Thus, tne NFC Regional Offices and headquarters can cocain information more quickly and i
accurately frem the resident inspector.
Imoroved Followuo The onsite presence of the resident inspector makes the entire
" inspection-detection-correction" system work more quickly.
The resident inspector is able to monitor daily the action a licensee takes to correct a cited noncomoliance. Further, resident inspectors can promptly direct the licensee's attention to potential problem areas.
Faster resolution of cited and potential problems means improved regulatory compliance.
The resident inspector also discusses NRC bulletins with the licensee and can observe that accropriate and timely action is taken.
Improved Public Contact The resident inspector represents NRC to local officials, other government offices, the local media, and the public in the plant neighbornood.
This role is secondary to inspection, but it provides a visible regulatory presence that did not exist prior to the resident inspector program.
After a resident inspector is assigned to a site, the resident inspector, his section chief, and the NRC regional public affairs and state liaison officers meet with local officials. The resident inspector is introduced, his and NRC's roles in normal and emergency situations are outlined, and points of contact with the local community are established.
The NRC Regional Office often issues a press release to local papers and radio stations about the resident inspector's assignment.
Unfortunately, 24 t
following the Three Mile Island accioent, some of these efforts were delayed uo to 3 months.
Most resident insoectors have been well received by the local cc:munities anc cress.
I.m reved CO.2..enicatien Nithin MRC The resident inspector functions as a ccmunication link to both the inspection and the licensing offices of the NRC.
The prime licensing office--The Office of Nuclear Reactor Regulation (NRR')--defines the detailed coerating parameters (the " technical soecifications") for each plant as part of the licensing precess.
Licensees often have questions about the orecise imolication of a technical specification under particular coerating conditions, and they consult the resident insoector fer interpretation, first because he is the NRC " presence" onsite, and second, because they feel he can often communicate more effectively with NRC headcuarters than can the licensee.
This insoection--NRR comunication link is of value to both NRC groups.
MRR is gaining firsthand kncwledge of the problems licensees face in interpreting and applying technical specification conditions.
The Office of Insoection and Enforcement is acquiring similar information and is clarifying its requirements for reporting violations of technical specifications.
4.2 ADVANTAGES TO TliE RESIDENT INSPECTORS Increased Personal Knowledge and Experience The resident inspectors feel that their presence onsite allows them to understand a particular plant and style of operation in greater depth than l
can a regional. inspector.
In general, they feel that this knowledge will make them better and more knowledgeable inspectors in future assignments.
25
Less Time kvay frca Hcme Less travel is a m2j:r plus f:r m s: r2sident inspectors. 'ihile work days are cartainly no shorter and increased backshift inscections may make hcurs less regular, the resident inscector scends considerably less Overnight time away frcm hcme than dces the typical regional ins:ector.
Less travel also means that some resident inspectors can, if they choose, more easily attend courses at local schools and participate in community affairs.
Career Potential The first residents transferred to reactor sites are now becoming senior resident inspectors and, as such, assuming a supervisory role as additional resident inspectors are placed onsite.
Resident inspectors also receive extensive training in technical and inspection skills. While ass gnment as a resident inspector does not guarantee promotion, it provides an opportunity for self-development and a chance to demonstrate quality performance.
The NRC intends that assignment as a resident inspec'.or will become an advantage in reaching higher levels in the NRC.
4.3 ADVANTAGES TO LICENSEES Consnunication with MRC The licensees appear to feel that the resident inspector's greater knowledge of their operation and his presence onsite enhances their comunication with NRC.
They state they can often communicate plant technical problems to the NRC much more effectively in face-to-face discussions with the resident inspector than in long-distance telephone conversations with an NRC Regional Office or with NRC headquarters.
They also believe that the resident inspector is more effective in communicating with NRC than are licensee. personnel.
The licensees also feel that the resident inspector's presence encourages quick resolution of 26
minor issues and often gives tnem prcmot clarification of tecnnical soecifications and regulations.
Attentien to Recuirements idost NRC cersonnel feel that the presence of a resident inscector makes licensees more careful, conscientious, and more aware of regulatory requirements.
Licensee oersonnel also seem to feel that way, explaining that it is " human nature" to be more careful when observed.
Whether this increased caution contributes to coerating safety is a matter of debate amcng licensees.
A substantial number of licensees contacted
- stressed that coerating safety was their, not NRC's, responsibility. While safety is indeed the licensee's responsibility, any increased care and attention generated by the resident inspector's presence is likely to result in safer operation with fewer noncompliances, i
Minimal Reculatory Burden After a resident inspector has been at the site for a few months,. licensees do not find his presence a burden. The resident insoector can conduct his inspections without a licensee escort and retrieve documents without assistance frcm licensee personnel.
His greater f amiliarity with plant details may more quickly allow him to assimilate the technical description of a problem and the circumstances leading to that problem.
He can pose his questions directly to the person best able to answer them.
- As recorded in (1) a recent GAO report, " Placing NRC Inspectors at Nuclear Power Plant Sites:
Is It Working?"; (?) an NRC Audit Report; and (3) interviews by Teknekron Research, Inc.
27
Onacino Observation and Correction of Problems Mest licensees have indicated that an inscection oregram that em: basi:es adrect Observaticn ratner tnan *scords -svisw gives a mere ac: urate cic:ure Of ncw weil anc safely a cian; is run.
They feel that correcting an errer in cas record-kesoing is not as relevant to safe coeration as is taking immediate acticn on a current prcblem. Licensees aopear to rescend mera cositively and cuickly when tne residen: inscactor points cut an
~
observed, existing crablem, and they have c:mmentad that prcrot resolution of current problems improves their cwn coeraticn.
More Informed NRC Response Licensees feel the resident inspector's ensite presence and kncwledge of their facility is a distinct advantage when an incident occurs.
Most residents live near the site and can get to the site more cuickly than can Regional Office personnel. In addition, the resident insoector can use his in-depth knowledge of the plant to provide NRC with accurate information about the context in which a problem occurred.
23
5.
DISADVANTAGES OF TliE RESIDENT INSPECTOR PROGRAM 5:Tementati n of :ne ris' dant inscec:ce or: gram has not :een :rcubie-9 e.
3me:i"i ca::ies are unavoidacle because they are inherent in the 3
asi ent inspecti:n ::nca :.
Cther prcblems c:uld have been minimized by better clanning and a Icnger ceriod in which to act; these essentially shcet-term pr0ciems are consequences of the transition to the resident insoec:cr prcgram, not of the program itself.
The informaticn en disadvantages is suppcrted by interviews conductec by Teknekren Research, Inc., under NRC Contract No. NRC-05-79-254 (See the i
Accendix for Teknekron's discussion of interview results.)
A recently released GAO recort on the resident program, " Placing Resident Inspectors at Nuclear Pcwer Plant Sites:
Is It Working?" and several internal NRC audits correborate many of these points.
5.1 DISADVANTAGES TO NRC Administrative Problems NRC Regional Offices have experienced a variety of problems in imple-menting the resident inspector program.
One of these--difficulty in supervising and maintaining contact with inspectors in the field--is unavoidable because it is inherent in the resident inspector concept.
In most NRC regions, the resident and his supervisor are in telephone contact almost every workday. These telephone conversations have become the major contact between resident inspectors and the rest of NRC.
Regional supervisors find it difficult to visit the sites because their own workload has increased under the resident inspector program.
l Logistical difficulties have also arisen.
The NRC sends the resident 11spector's mail to the nearest post office (often 15 to 25 miles away),
and he makes a daily pick-up at the expense of time that could be used in 29
insoection.
More than 15 percent cf scme resident inspectcrs' time has been devoted to mail pickup.
Scme resident inspectcrs have not received ccoies of updatec licensing cocumencs relating to the site; others receive tco much cuclicaca mail anc scera cc9s'03ricle ties screer M; 200 * 'i7g.
Steps are now being taken :o solve some of these creolems:
for examoie, part-time clerical he!c is now availacie in scme resident effices, and improved mail delivery together witn a more organized accroach to assuring full document di'stribution was recently instituted.
Nevertheless, the secaration of resident offices, regicnal offices, and NRC Headquarters may continually breed problems in communications and administrative suoport.
Manocwer Problems Of more concern is the " manpower drain" that staffing the resident inspector program currently places on the regional insoection program.
The senior resicent inspectors now cnsite and those scheduled to go onsite in the next year ccme primarily frcm the ranks of experienced principal inspectors. The rapid staffing of resident positions has, in some cases, depleted the regional staff of "generalist" inspectors, and there is concern that the regional inspection program and the regional capability to respond to incidents will suffer.
These experienced principal inspectors are also those next in line for promotion, and placing them onsite directly conflicts with the need te expand the regional supervisory staff in response to the resident inspector program.*
These factors are unavoidable in an inspection program that must be staffed with highly qualified, experienced people.
However, they might not have been as serious had the program been staffed more slowly or had the NRC been willing to bring people from NRR into I&E.
More measured
- Resicent inspectors are not barred frcm applying for promotion while onsite.
Yet many of them bave stated that they feel the resident inspector, program will be more effective if staffing changes are minimized.
Others are not prepared to suffer the costs of another household move so soon.
30
staffing would have allowed the pool of talent in the Regional Offices to shift more gradually by providing for more regular replacement.
But or ba!anca, 'RC believes nat the berafits f early site assignmen: cf resi: ants ins:sc :es u '.. sign 9 ace :n:-:- arm man cwer ?r:blems.
?otential fer loss of Objectivity The day-to-day exposure that provides the resident inspector with an extra dimension of knowledge about the plant is also the factor that may.ead to a major concern of both Congress and the NRC:
loss of objectivity. While loss of cbjectivity is a real concern, the majority of NRC regional and headcuarters staff feel that current resident insoectors' cojectivity has not been comoremised.
Regional section and branch chiefs, who supervise and have almost daily telephone contact with the resident inspectors, have as yet found no clear evidence of loss of objectivity, though they are attuned to the conversatior.al hints ("my licensee") that may indicate a problem.
The resident inspectors themselves are highly conscious of the accearance of such actions as carpooling with licensee personnel, though avoiding them may cause considerable personal inconvenience.
A few regional and headquarters personnel are less convinced about the resident inspectors' objectivity.
Scre of them base their position on a feeling that resident inspectors may cite fewer noncompliances than regional inspectors.
However, it is not clear if or how numbers of noncompliances might indicate an inspection program's objectivity or effectiveness.
Efforts that bring licensees inte compliance with regulations might in fact produce fewer noncompliances over time.
This issue will be addressed by Teknekron Research, Inc., as part of ^ its evaluation of the Revised Inspection Program.
Potential for loss of objectivity was the major obstacle to establishing the resident inspector program,* and considerable thought has been given
" Similar concerns were expressed by other Federal agencies. See the NRC-contracted study of other agency inscection and enforcement exoeriences:
NUREG/CR-0051 and NUREG/CR-0052,
" Evaluation of Inspection and Enforcement Programs of Other Regulatory, Safety, and Professional Organizations."
31
to the actors that may contribute to such a loss.
Frequent contact with the licensee and isolation from NRC are the major factors.
NRC has included a variety of program features intended to limit the effect of increased licensee contact.
Proscective resident inspectors are selected to minimize this concern; only balanced,
- mature, ana indecencent inspectors are chosen for site assignments.
A resident inspector is not assigned to a site if he was recently employ d by the operating utility.
The ore-transfer training for prosoective resident inspectors warns about loss of objectivity and suggests precautions to be taken. The NRC code of conduct strictly limits relationshios of inspectors and licensees, forbidding inspectors to participate in licensee-sponsored social or recreational events and even in licensee carpools.
Resident assignments are of limited duration--3 to 5 years at any one site--since loss of objectivity appears more probable in longer assignments.
The most effective way of insuring against loss of objectivity may be to provide a peer with whom the resident inspector can interact.
This was consistently recomended by other agencies with a resident inspector program (see NUREG/CR-0051).
The expanded resident inspector program now places a minimum of two resident inspectors at each operating reactor site, though the more junior inspector will not be a true peer, particularly, since currently, many junior inspectors have no prior NRC experience, although all have nuclear experience with a utility or the Navy.
Feelings of isolation from the NRC can also result in loss of objectivity.
The fairly remote location of many reactor facilities inevitably strengthens feelings of isolation, as does lengthening assignment as a resident or reassignments from one site to another. The resident inspector program is too new for specific examples of isolation to have surfaced, but general solutions have been adopted. NRC regions are beginning to schedule periodic meetings of resident inspectors where site and office issues can be discussed among the residents and with regional management.
A l
Headquarters staff member usually participates in these meetings both as a listener and as a discussion leader. Resident inspectors receive copies of the reports generated daily by each Regional Office. Supervisors maintain frequent telephone contact with their residents.
32
Assignment of additional resident inscec: Ors tc a site should heio prevent feelings of isolaticn.
All coerating sites mannec by the end of fiscal year 1_:20 are to have a minimum f twc residents, :n: four si as aili have tree resi:ents.
- Aany site Of"icas will al:0 uia car:- 'me clerical assistance. With a :molement of :nree to f 0ur NRC amolayees, feeli ngs af isolation shoulc te snarply recuced.
1 S.2 DISADVANTAGES TO THE RESIDENT INSPECTORS Perscnal Difficulties Resident inspectcrs have encountered a number of personal problems, some of which are unavoidable.
First, locating a senior resident at a site usually requires moving his family, the sale of one hcme, and the purchase of another. Even the smoothest relocation always causes some strains, and some disruptien cannot be avoided.
High mortgage rates have made home sale and purchase more difficult.
Moreover, current government reimbursement policies generally do not cover the full amount of relocation and settlement costs, and many resident inspectors have lost money:
the average loss is $5,000, and a loss as high as $14,000 has been reported. Residents also complain about the excessive time involved in processing reimbursement pacerwork, and scme resident inspectors have carried the entire financial burden of relocation longer than necessary.
Since many reactor sites are located in relatively uncopulated areas, it is scmetimes difficult to find satisfactory housing nearby.
Availability of suitable schools often dictates the choice of housing for famili13 with young children.
A number of resident inspectors have been forced to relocate farther from the site than they had been from the Regional Office, and the increased commuting cost is not currently reimbursable.
These problems can be severe:
financial penalties in a time of high inflation place a substantial and perhaps unwarranted burden upon these 33
carticular emoloyees.
A task force under tne Executive Director for Coerations is exoloring ways to ease these ourcens, including legislative acticn that nay be recuired.
The resi:en inscec:ars anc : heir f1milies also f ace personal and social c0sts.
The inscectcr's Ccde of Ccncuct prohibits :ertain activities that c uld lead the casual cbserver to suscect that a resident inscector was no:
Objective:
f r examole, the resident inspector may ne,t carpool with plant employees, use the bus coersted at scme sites, or join in license.
~
g sconsored activities.
These requirements also F.xtend to the resident inscector's f amily.
In small c mmunities where the utility may be One majcr employer, this sharply limits the social contacts and recreational appertunities Open to the resident inspector and his fanily.
There have been a few attacks by Iccal press, officials, and intervenors on the integrity of resident inspectors.
In such cases, the resident and his family, as the local NRC " presence," are personally exoosed to hurt from which they would otherwise be shielded if they were located at an NRC Regional Office or in NRC headcuarters.
It is often difficult to respond with aapropriate support, and an acequate solution to such situations has yet to be developed.
Job Isolation Placing resident inspectors onsite full time isolates them from the main-strewn of NRC activity, an isolation that has both personal and profes-sional elements.
They are removed from the daily contact with other NRC inspectors and their supervisors in the NRC Regional Office; they cannot participate in the informal exchange of information that occurs in any large office.
This type of isolation is inherent in the resident concept.
The often-daily telephone call by the regional supervisor somewhat mitigates this isolation, as does the contact with the regional inspectors who visit the sites at least monthly. In some NRC regions, residents scend one or two days a month in the Regional Office, but this limited exposure, 34 E
9 usually for training, is only a small antidote against feelings of isolation. The addition of a sac:nd resident inspector wi.ll substantially reduce personal isolation, but it cannot counteract the orofessional isciation inneren: in :ne joo.
5.3 DISADVANTAGES TO LICENSEES As a group, the licensees have experienced fewer problems with the resident inspector program than have NRC and the resident inspectors.
Dollar Costs Licensees are required by law to provide office space, utilities, and janitorial service for the resident inspectors.
Few licensees could i
readily state dollar costs for the amenities, though the range seems quite large, depending upon the availability of space at the site.
In one case, the site administration building was being expanded, and space for the resident inspector could be provided at essentially no additional capital cost.
In another case, the licensee purchased a trailer for use by the resident at a cost of $42,000.
NRC provides all office furniture and equipment, telephone,
- copier, and telecopier service, and part-time clerical help.
Inspection Impacts Licensees had expected the nwnber of regional inspection visits to decrease with the advent of the resident inspector program, on the premise l
that the " principal" inspector would now be stationed at the site and only specialist inspections would be conducted by the Regional Office.
(Licensee personnel generally acccmpany region-based inspectors and retrieve dccuments for them, but the resident inspector does not need these services.) Regional inspection has in fact not diminished, mainly due to l
the increased number of inspections following the Three Mile Island 35 E
t e
the level ~of inspection. has been accident.
Licensees recognize that influer. cad by Three Mile Island, and the impact of the resident inspector procram on the amount of recional inscectien--and the licensee mancower recuired to succor that recional inscection effort--cannot as yet ba Evalultac.
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CCNC.USION Juring tha 1 13 ; :ne ard :ne half years, NRC has gained censicer2:le e.ceriince in 7 liman:ing and managing the resident inspector program.
4 100 rec:gni:es Inc ud anticipated Ccngress' c:ncerns:
I J
No single inscector is qualified in all technical areas:
regian-i:ased inspections supplement the residents' activities, resident inspectors are assigned according to their excertise, and all resident inspectors receive suostantial training.
e Loss of objectivity is a valid concern:
a variety of program measures help to minimize the potential effects of isolation frem NRC and increased contact with the licensee.
To date, there is no clear evidence that any inspector has lost objectivity.
The resident insoector program has expanded in scope and is being implemented more rapidly than originally planned:
The increased staffing goals for the close of fiscal year e
1980 are being met:
more than 36 percent of the residents are now onsite and inspectors have been selected for more than 60 percent of the remaining resident positions.
e Program goals have been achieved or are being met:
average onsite inspection time has more than doubled, direct verification of licensee activities has substantially increased, and an NRC regulatory ' presence is highly visible.
NRC has found that managing a dispersed inspection force requires close coordination and realistic planning:
e Establishing and manning many separate resident offices has created problems:
increased administrative burdens have been placed on both the resident inspectors and regional office staffs, and the regional pool of experienced NRC inspectors has been temporarily diminished.
l l
37
s Scoping the full range of implementaticn needs is diffi-cult:
racid expansion of the crogram demands that currently clannec tasks be redefined and that new tasks be addea on snart notice, s
The resicent inscec;crs are 1 cec li n ers nal difficulties:
relocation is an often-heavy financial
- burden, his s:cial and
- ersonal activities may be restricted, and the jcc requires eersonal and crefessional isolation.
Legislative crecosals tay be recuired.
NRC is addressing these prcblems and should have several of them resolved within a few months.
Mcwever, most of these problems appear to be consequences of the transition to a resident insoector or0 gram, and we believe they are outweighed by the benefits:
e The type and quality of information gatnered by the inspection program has changed:
NRC acquires broader, deeper knowledge of a licensee's operation by the resident inspector's direct observation of licensee actions and through the increased time he scends onsite.
e Comunication between NRC offices has imoroved:
the resident inspector is a communication link to both the Office of Inspection and Enforcement and the Office of Nuclear Reactor Regulation.
e Licensees respond favorably to the program:
they communicate with NRC more readily and effectively through the resident inspector, they believe the resident inspector program provides NRC with a more accurate view of their operation, and the resident inspector does not disrupt licensee activities.
Public acceptance of the safety of nuclear power may be e
enhanced:
prompt resolution of problems is encouraged and the presence of the resident inspector may reduce public anxiety.
e 1
- !8
7.
REFERENCES 1.
'R 4:ce: *:o. 95 '.'?9.
- Irt I.
35 n Cc gress, 2nd Sessicn, May 15,
. 53, ic::m: n;. n; M __idd.
2.
Evaluati:n cf the Rasicent Inscacticn Trial Procram, jffice of insoec:1cn anc infcrcement, U.S.
Nuclear Regulatory Ccani ssion, SECY77-128, January 23, 1977.
3.
Study Recort. NRC Insoaction Alternatives, Office of Insoection and i
Enforcement, -U.S. Nuclear Regu latory Ccmmission, SECY77-138A, Aoril 1977.
4 Revised Inf.cection Procram for Nuclear Power Plants, Office of inscec:1on anc inforcement, U.S. Nuclear Regulatory Commission, NUREG-0397, March 1973.
5.
Incecencent Verification Cotions for Insoectino Nuclear Pcwer Plant Facilities, Sandia Lacoratories, Sand 79-1038, NUREG/CR-0826, Septemoer 1979.
6.
Career Fields for Insoection and Enforcement Personnel, General Researen Corporation, NUREG/CR-0042, Oc:coer 1978.
39
APPENDIX: PERCEPTIONS CF TiiE RESIDEhT INSPECTCR PRCGRAM L'ncer Con rac: "RC-05-79-25c, "RC asked e<nekren Resaarch, :nc., ::
~
interview NRC headcuar.ars and regicnal staff, resicent inspec::rs, anc ifeansee persennel to determine tneir.perceptiens of the resi:ent insoector program. NRC felt that all parties would responc mere acenly to an indepencent group than to interviewers more directly affiliated with NRC.
The remainder of this section has been structured and authored by Teknekron Research personnel and has not been edited or otherwise modified by the NRC.
A.1 LICENSEES' PERCEPTIONS OF TiiE RESIDENT INSPECTION PROGRAM t
Teknekron Res3 arch interviewed 62 utility employees working for six licensees anc. spoke with approximately equal numbers of people in the corporate effices and at the plant sites.
Typically, Teknekron interviewer; a senior manager, several middle-level managers, and working level emr,loyees at the corporate offices, and the superintendent, shift supervisors, and working-level emoloyees at the plants.
Our* questions were designed to elicit the interviewees' perceptions of several aspo.t.
of the resident inspection program. First, we* sought to determine their feelings about the NRC inspection program that existed prior to the Revised Inspection Program to provide a baseline against which their feelings about the revised program could be assessed.
Second, we sought to determine the interviewees' feelings about the concept of resident inspection, in order to discern which perceptions reflected their understanding of the idea and which reflected their experience with the actual implementation of the program. We also touched on how the licensees interact with the resident ~ inspector,. how the program has affected the licensees' comunications with the Regional
- Office, and their
- As stated above, this appendix was prepared by Teknekron Re' search. Such terms as "our" and "we" refer to Teknekron personnel.
l l
A-1
t feelings about multi le residents on a site. Thira, we sougnt to detennine if the licansees had cnanged (cr expected to change) their oceration or management because Of :ne presance of the resican: ins:ec:cr.
? cur:h, we wantec Oc cetermine ane:her the licensees thcugnt the *asiden: cr: gram had changec the outlic's view cf them anc of NRC.
Last, we askec snat :ne licensees felt accut tne increased NRC emchasis :n direct Observation and independent measurenent.
Coinion of Previcus Inscecticn Program Almost all licensee resocndents felt the efficiency, quality, and impact cf the NRC inspection effort were determined much more by the charac-teristics of the individual inspectors than by the written specifications of the program.
The respondents felt that the inspectors were generally comoetent, thcugh many licensee personnel stated that inspectors who had field experience, particularly in reactor cperations, were more likely to focus on things the licensees felt were useful'and realistic.
Several of the resoondents felt that the accident at Three Mile Island has, for the time being, overshadowed the influence of the regional inspection program.
Most felt the frequency of inspections has increased many fold in the last five years and could be reduced without risk; they also felt, however, that the increased inspection frequency resulted from public pressure on the NRC, and that this pressure was not likely to decline.
Interestingly, some QA personnel felt the NRC inspections could be more productive if more frequent and less structured.
Licensee management was frequently concerned about the manpower required to respond to each NRC inspection.
Specifically, many managers felt that following up on each inspection required a great deal of time spent on paperwork, thus diminishing the time the staff could spend on their plant (safety)-related duties.
In general, the licensees felt they had to live with the NRC inspection program, regardless of their feelings about it.
A-2 l
Ooinien of the Resident Inscection Ccncect
- 'e s: of ne interviewees did rc: Overtly distinguish their per:eo:icns of the resident ins:acticn concac: f'cm ILE's imolementation of tnat : ncact.
However, their c =ents reveal h:w the resicent inscection pr: gram has affectad them and wnat :ney :nink about both the regional and resident inspecticn pr: grams.
Most of the interviewees felt that the resident position, to a greater degree than a regional inscector casition, required keen tecnnical and inter:ersonal skills.
Essentially all felt the quality and impact of the resident inspection program are determined more by the characteristics of the individual inspectors than by the written specifications of the program. Many indicated tnat if asked a question by an inspector who they feel is personable and focused on " big picture safety issues, they feel more inclined to offer more information than the questien might demand.
Mcwever, all indicated that their relaticnship with the resident inspector is or would be professional, respectful, and cooperative.
All respondents felt that a resident inspector has more opportunity than has a regional inspector to get to know their plant, their staff, and their method of operation. The respondents had experienced or expected a number of benefits from the resident inspector's greater knowledge of their operation, and they recognized that NRC also benefitted. The resident can do much of his inspection without a licensee escort and much of his document retrieval without assistance from licensee personnel; he can more quickly understand the technical description of a problem and the circum-stances leading to the problem.
The resident can pose his questions l
directly to the person best able to answer them, and he can coordinate regional specialist inspections and focus them directly upon areas warranting NRC scrutiny.
The resident can provide NRC a greater under-standing of the licensee's operation.
l l
In addition, the licensees felt a resident's greater knowledge of a utility's operation and his presence onsite could enhance licensee /NRC comunication.
They felt descriptiens of plant technical problems are A-3
c:municated to NRC (both ILE and NRR) much more effectively in prcmot, f ace-t0-f ace discussions witn a resident insoector than in long-dis:ance
- alachone :nversations with a Regicnal Office, and the resident, in turn,
- an ::=unicate mere effectively tnan the licenses di:n ::her NRC Sersonnel.
The licensees also felt that the resident inscactor's proximity encouraged prompt resolution of " nickel-and-dime" issues thr: ugh f ace-to-f ace discussions and afforded promot clarification of technical specifications and regulations.
Although pleased with the prospect of the residents' enhancing corrmuni-caticns with NRC, most of the interviewees felt the placing of a resident inspector at their plant offered no more intrinsic reward than would having a policeman in their home living rocm. Those licensees with no resident or who had had a resident only for a short time were concerned that the resident inspector's presence might make the plant staff nervous.
They were concerned that the resident might intrude en " brainstorming" in plant staff meetings or interrupt staff activities.
Tnese interviewees also expressed concern that plant management might have to shift priorities from wnat it considered important to safety to whatever the resident
+
censidered important.
Licensees that had more experience with a resident inspector appeared less concerned about these possibilities.
Almost all interviewees felt there was not enough "inspectable activity" at their plants to keep more thar. one resident inspector busy.
They felt placing more than one inspectar on their sites would waste NRC manpower and would not increase the number of findings of items significant to safety.
A few interviewees felt that NRC probably had to increase the number of residents at each site to assure continuity of inspection quality and to handle onsite work administrative.
Changes in Operation or Management with RI on Site A majority of the interviewees felt the presence of an NRC resident inspector on site would make the plant staff more conscienticus about A4
license recuirements, their resoonsibilities, and safety, simoly because it is human nature to be more cautious when being cbserved. About half of the majority feit accec conscienticusness, cautien, and attention to de ail sy tna slant staff acaid erhince ne safety of tne Ocerating f acility, and half felt this wculd not annance safety.
A few of the intarviewees felt acded attentien to written detail could slow work ano discourage free-thinking encugn :: decrease safety in the ocerating clant.
A large minority (close in numoer to the majority) of the interviewees fel the plant staff and management are already highly motivated to do their very best.
This group felt the cresence of a resident inscector would neither increase nor decrease that motivation.
Essentially all of the licensees indicated they consult the resident inspector for clarification of regulatory requirements, much as they did with their principal inspector when he was based in the Regional Office.
However, they do net usually censult him for technical input.
They felt very strongly that responsibility for running the plant safely rests solely with the licensee Thus, though they might ask a resident how other utilities solved a particular problem, they did not ask the inspector to decide what solution they should implement.
Licensee Ooinion on the Public's View of the Licensee and NRC Most of the licensees interviewed felt that the public knows little about the resident inspection program. They felt that the public probably would feel safer with an NRC man onsite, if the public knew more about the resident program.
The licensees felt such a sense of comfort might be misplaced, because they feel safety is influenced more by utility management attitude than by the presence of NRC. Some were concerned the public might feel their plant was a poorer performer because "NRC thought it necessary to put an inspector there all the time."
Most lfcensees felt the general public, if informed about the resident program, would think more positively of the NRC for instituting the A-5
crogr am.
All the licensees interviewed felt the resident inscection program was less significant than the Three Mile Island accident in inf:uencing tne ;2clic view of nuclear utilities and tne NRC.
Jirecc Cheervaticn Tha licensees generally felt neutral about NRC increasing its direct coservrtion cf their activities, if it would not interfere with their personnel and normal ooerations.
Although licensees did not welecme greater NRC inspection, they consistently indicated that, if they wanted to know how well (i.e., " safe") a plant was run, they wculd rely more on observation of licensee activities than on records review.
Scme inter-viewees were quite negative about the prospect of greater NRC observation and verification, fearing it would inevitably disrupt normal plant coeration and require additional reporting.
Sunnary of Licensee Percentions The, licensees' perceptions of the resident inspector program reflect their fundamental feeling that the quality of any inspection program depends more on the quality of the inspectors than on the written specifications of the program.
In general, they see enhanced communication with NRC and the residents' greater knowledge of the facility as advantages to both them-selves and to NRC.
While a majority of the licensees felt that the presence of the resident inspector made their staff more conscientious about requirements, feelings were mixed about the effect of this conscientiousness on safety. Licensees whose residents had been onsite for a substantial period did not feel this presence hampered or intruded upon their normal activities.
A-6
A.2 NRC PERCEPTIONS OF THE RESIDENT INSPECTOR PROGRAN We interviewed 25 staff members in :ne five NRC regicnal effices and sign:
- eccle in head:uar:ar:.
In addition, 3e c:cka with eight residen inscec: Ors; :neir :er:ections are cascussac secarataly.
In each of the regional offices, we al'<ed witn the Director, the Chief of the Reactor Operatiens and Nuclear Succort 3 ranch, and usually, the latter's section chiefs, plus other inscection cerscnnel.
In headcuarters we socke witn division directors and middle level managers.
We discussed each person's feelings about the inspection program that existed prior to the Revised Inspection Program and abou: the resident inscection concent.
They were also asked what effects the resident inscectors have had on the licensees, on the regional office, and on NRC ccmmunications with the licensees and with the public. We also asked what they felt was an approcriate tour of duty for a resident inspector, what oroblems the residents had faced, and what the residents' feelings were about their positions.
Last, the staff was asked what benefits and problems greater direct observation and the unit resident concept pose. The resocnses to these questions are discussed belcw.
T Opinion of Previous Inspection Program i
Most of the interviewees felt the previous inspection program adequately assured licensee compliance with regulatory requirements.
Usually, they described the past inspection program as less structured and less confining for the inspectors. Some felt the past program did not probe as deeply as the revised program but did assure licensee compliance in areas each inspector considered important to safety. Most also felt that a less defined program was feasible in the past because most inspectors had many years of reactor operations experience but that such a program would be less reliable when the average experience level of the inspection force is lower. The development of the modular inspection procram* was seen by most
- Written spec 1fication of.the inspectors' activities.
l
\\
(
t to be necessary because of the racio increase in tre nurcer of inscectors and the increased difficulty in finding senior, ccerationally exoerienced ins:ec:ce recrui:s.
Mos:
ecole fei: :na: the written specification of inscect:r crictice 01: 10. cicassarily ssui: in a 'better" insoection Or: gram, ai:ncugn it ci: create a Scre stancarci:sc :r: gram.
Coinien of the Resident Insoection Conceot l
Most of the regional interviewees did not distinguish their cercections or
[
the RI concept frcm I&E's imolementation of that conceot. Nonetheless, it was cossible to discern in their answers what benefits and problems they feel the resident inspection program and its imolementation pose. Scme of the heacquarters personnel clearly separated their thougnts cc :he concept frcm those on :ne implementation, and this separation is practically the only factor that distinguishes regional frem headquarters responses. More than half of the headquarters personnel did not favor the concept at the time of the trial program but generally became convinced that more inspection time would probably result, and that the clearly increased onsite time could provide knowledge about the licensee that was not obtain-able through region-based inspection.
Indeed, most regional and headquarters respondents felt that the resident inspector position provides an unprecedented opportunity for the agency to learn more about the licensees' operations than it could learn under the region-based program.
They felt that, through the resident, NRC learns more about the quality and nature of day-to-day plant operations, the attitudes and capabilities of plant management and staff, and the technical subtleties of the particular nuclear plant.
They felt the resident could spend more time than region-based inspectors observing licensee activities, rather than reviewing records. Also, they felt that, through the resident, NRC knows more about the circumstances leading up to any problems occurring in the plant.
Most felt that this combination of additional knowledge enhances NRC's understa. ding of the plant condition l
A-8 1
(i.e., " safety") at all times and NRC's adeptness in rescending to aoncemai incidents at the plants with residents.
The regicnal persennel often re:Orted they found they c:uld use their regional ins:sc:ica fccce mere efficiently :y following u: cn licenses saaknessas incicated by :he resi:ent ins:ect:rs.
Scme regional supervisors also fel: they cou!c manage more eff ectively by asking tne residents' ::servations cn inter-actions between regional insocctors and licensee perscenel. Most recional and some headquarters personnel also felt the resident position offered NRC the opportunity to develop greater racport with the licensees, to improve the licensees' understanding of regulatory recuirements, and, cy developing a greater influence en management attitudes, to enhance the puolic health and safety.
In additien to the several benefits discussed above, headquarters and regional staff also felt the resident inspection program poses a number of problems for NRC.
Foremost in the minds of most interviewees was the Ocncern about maintaining inspector objectivity in the resident position.
Some of the interviewees felt a loss of objectivity was probably unavoid-able because the residents would be " isolated frcm NRC peer support (of the firm regulatcry philosophy under which they live)," and the residents would be imersed in a " hostile, anti-NRC, pro-nuclear" atmosphere. A very few people felt that many resident inspectors had already lost objec-tivity, based on their personal perception that resident inspectors filed fewer noncompliances than regi]nal inspectors. Scme interviewees felt the selection of mature, experienced inspectors and close regional supervision eliminated their concerns about potential loss of objectivity.
Others felt there was no potential for loss of objectivity, because there are no incentives for the residents to be less objective than regional inspectors.
In addition, they felt that the breadth and diversity of the inspection program requires a comparable breadth and diversity of inspectors, which minimizes the influence of one inspector on NRC's assessment of licensee compliance and plant safety.
Many of the inter-viewees felt the resident position requires additional 1-terpersonal skills for the inspector to be firm without antagonizing the licensee and A-9
b breaching c:nfidences established with licensee personnel.
Several regional suoervisors were concerned that an inscector olaced in a resident i
- osition is less available to contributo to the regional talent cec 1 to hancle Oreblems tna 1 rise a: otner plant:.
The staff also cescribeo several prcblems that they felt resulted fr:m the accelerated icolementation of the resident prcgram.
Specifically, the regional staff recorted that a variety of administrative prcblems have acceared, becaufe moving the resident inspectors out of the regicnal office did not remove the administrative worklcad associated with this addition to the inspection program.
Regional administrative personnel wanted clearer guidance on their responsibilities toward the residents.
Regional supervisors felt challenged to modify their managerial methods to cope with the new problem of supervising an inspector with whcm they caninunicate primarily by telephone.
Both heacquarters and regional staff were concerned that a rapid staffing of resident positions would require NRC to be less selective in its hiring of new inspectors.
A few head-quarters people focussed on high-quality
- staffing, of both the accelerated and the " original" resident inspectcr program, as tne major problem the program faces.
Changes in Licensee Operation or Management with RI on Site Most of the regional staff felt licensees were more cautious, more conscientious, and more aware of regulatory requirements with NRC's presence onsite.
One staff member felt the licensee personnel conducted themselves more professionally and with greater discipline with a resident inspector onsite.
Another staff member felt the licensee's awareness of NRC regulations was enhanced by the continual presence of an NRC " inter-preter" onsite.
Some felt the resident inspector program was no more effective in assuring licensee awareness of NRC regulatory reouirements than the regional inspection program.
They felt the licensees had not changed since getting resident inspectors.
A-10
o Chances in the Oceratien or Manacement of the Recicnal Office Mos: Of ne interviewees felt they could not secarate the effects of the
- cs:-Three tie ::'and werticic 9:n ne effect: Of :he resident inscect:r Or0gran on the regi:nal office.
Many felt there had ?rcoably been no cnanges in eneir Oceration or management.
Most felt tne relaticnshio an ins:ector had with his peers and his su erviscrs did not change much after he assumed a resident position. The section chiefs reported they now scend much of their time assisting the resident insoector instead of managing.
Some regicns indicated they hooe to alleviate this problem by designating
resident coordinators" in the regional office to perform services that the residents recuire and cannot accomolish via telechone, services which the section chiefs new provide.
Most of the interviewees felt the residents' proposed length of service at one site (3 years) was about the optimum. Most felt a shorter stay at one site (i.e., moving more frequently) would unf airly disrupt the lives of the residents' families.and not give the residents time to learn their assigned plant well and to use their kncwledge of the plant effectively. They also felt a longer stay en ene site would make it more difficult to assure inspector objectivity and freshness.
Comunications with the Licensees and the Public Almost all felt NRC's public image has been improved by placing resident inspectors onsite. Most also felt NRC's comunications with the public had improved but were largely influenced by NRC's ccmmunications with the local press, which some regions still handle exclusively through the regicnal Public Affairs Officer.
The regional personnel indicated most licensees and NRC staff treat the resident as the orincipal inspector.
Hence, all communic 3tions between the licensee and NRC go through him, as they used to go through the principal insoector based in the regional office.
A-11
t Residenf '.ascector Preblears l
Regional cersonnel incicatec some resicent insoec:ces feel lonely, because they no lenger have inf:r :ai c:ntact witn peers and are i:clnad "Om :ne mainstream of regional regulatory activities.
Regicnal interviewees recorteo tne resicents usually lost money in moving to their sites for several reascns, such as 1) the government's reimbursing less than the total cost of moving, 2) moving to an area with a higher cost of living, and 3) lenger comuting distance and cent:ensurately higher ccmuting costs.
Interviewees indicated residents often took their positions in the i
belief it would increase their cromotional prosoects and give them greater independence en the job.
Scme interviewees stated the residents new feel their prospects for promotion are not as bright as premised. The regional interviewees said the residents welecmed not having to travel as much as regional inspectors but were often forced to avoid social contact with their neighbcrs, who usually work for the licensees.
Independent Verification and Additional Residents Many of the regional staff consider direct observation to be a large part of the present, region-based inspection program. Some felt an independent measurement program could be very expensive and could lead to NRC's becoming the nuclear industry's acceptance testing laboratory.
Scme personnel were concerned that a greater direct observation / independent measurement program could interfere with licensee personnel in their normal execution of duties and hence
% safe operat' e n of the plants.
Many felt a greater emchasis on direct obseru 4n/inA indentmessurement would give NRC greater knowledge of licensee o
-v 'ons and greater r
credibility with the public.
They also felt indepenc ot verificaticn offers the benefit of promet ("real-time") rather than,u cost facto correction of deficiencies.
A-12
as noted previously, the staff is concerned that staffing resident inscector positiens will recuire NRC to be less selective in its hiring of new inscectors.
The regicnal staff feels that clacing additicnal resi-dents 2: each 3ite will exacarba a :nis Octantial cr0blem.
Icme of the regional sucervisers noted tha: Uni: *ns ec: Ors were to be hired "directly Oc the sites.
They felt it is easier to select inscect:rs mos: accro-priate for eacn clant/ licensee ccmoination if they have wor'<ed with the inscectors long enougn to '<new :nem well.
Resident Inscector Percentions of the Resident Insoection Procram Eight residents in four NRC regions were interviewed. Their cerceotions of resident inscection parallel the regicnal staff perceptions of the pregram.
They felt their day-to-day contact with plant staff and manage-ment gives them much greater opoortunity to observe licensee performance, attitudes, and capabilities. The residents felt this allcwed NRC to better understand the events and f actors affecting nuclear plant safety.
Most residents felt the licensees had beccme more conscientious about safety and more aware of regulatory requirements because of the resident inspection program.
Scme residents felt the licensee staff found the presence of the resident useful in persuading management to update older plant features or less effective plant practices.
Congruent with NRC's philosophy that the licensees bear primary responsibility for plant safety, most resident inspectors felt their principal duty was not to intercede in the licensees' decision-making, but to assure licensee compliance with the NRC regulations.
The residents felt their optimum length-of-service at one site would be between three and five years, for the smne reasons cited by the regional staff.
They usually felt ccmmuni-cation with the public and the licensee had improved with placement of resident inspectors.
The resident inspectors mentioned a nwnber of
- problems, such as moving costs, less than premised prospects for promotion, isolation from regional peers and activities, lack of clerical help, and l ac'k of premised government cari.
The residents generally A-13
1-I flycrs;.greatar direct cbservation as a ' way to evaluate licensee perfor:ance. They felt a second resident could facilitate greater direct coservation and alleviate some of their acministrative burcen, once he was l
j tilined. Thiy ;a.9ar1Ily fal: : Mat, :n the ahole, residant inscection nas 1 Jcac cencact, :u: is imolemented thus f ar, the program has taken.mcre than it has given them.
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