ML19341A530
| ML19341A530 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1980 |
| From: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Ahearne J, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19341A503 | List:
|
| References | |
| FOIA-80-516 NUDOCS 8101260260 | |
| Download: ML19341A530 (59) | |
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REPORT TO THE COMMISSION
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INFORMATION REPORT ON THE NRC'S FORMER REACTOR INSPECTION PROGRAM l
NOTICE This is An IntemalManagement Document Reparedlo'r The Ccmmisshn Not 1b Be Released GutsWe of NRC t.
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9 JULY 1980
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OFFICE OF INSPECTOR & AUDITOR U.S. NUCLEAR REGULATORY COMMISSION 82022eo g o
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C WASHING TO N. D. C. 20555 July 31, 1980 MEMORANDUM FOR: Chaiman Ahearne Commissioner Gilinsky Commissioner Hendrie C
issioner Bradford v.
umr ngs, d=r ctor FROM:
1 es Offi of Inspector lifid Auditor
SUBJECT:
REVIEW 0F NRC'S REACTOR INSPECTION PROGRAM o
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In December 1976, the Offic' of Inspector and Auditor (0IA) initiated an y
audit review of the Nuclear legulatory Commission's (NRC) reactor inspection program. The primary objective of our review was to assess the degree to which the Office of Inspec; ion and Enforcement's (IE) policies and procedures for inspecting con iercial nuclean power reactors were being successfully implemented and, if appropriate, to recommend improvements.
However, in November 1977, ou. audit was interrupted due to two high priority investigative assignments and other subsequent audit assignments.
Although the attached report deals principally with the power reactor inspection program as it existed prior to July 1978, we believe it provides an objective overview of the reactor inspection program, and much of the material still has value against which to compare the emerging resident reactor inspection program.
Our review was conducted at NRC Headquarte'rs and Regions I, III, IV, and V.
We examined pertinent inspection records and had discussions with regional directors and their staffs and with officials of IE Headquarters' Divisions of Reactor Construction Inspection and Reactor Operations Inspection. As part of our review, we accompanied regional office reactor inspectors to observe the actual conduct of construction, operations, and decommissioning inspections.
In addition, we conducted a survey of field inspectors in Regions I, III, IV, and V through the use of a questionnaire and obtained the inspectors' views on the inspecticn program.
We also met with upper management officials of 23 utilities to obtain their views and concerns regarding the NRC reactor inspection program.
The report does not disclose any serious deficiencies in the inspection program areas we examined.
Generally, 0IA's impression was that, at the regional level, the region-based reactor inspection program was well managed and that inspections were being performed at, or near, the proper time intervals. We did note a relatively higher percentage of "not-clear" inspection modules for the operations phase inspections. We believe this may be indicative that more inspection effort should be applied during the earlier constructic.1 pemit, preoperational, and test and startup inspection phases, particularly during the period immediately prior to and following the issuance of operating licenses.
Contact:
H. Boulden, 0IA 49-27051
c i,
.The Commission 2
Although the NRC's reactor inspection program has changed with the advent of the resident inspector concept, we believe the attached report gives a comprehensive evaluation of the reactor inspection program prior to the change. We believe this information may be useful to the Commission in making decisions concerning the futura course of the NRC's reactor inspection program.
AGENCY COMMENTS In commenting on our draft report, IE with the concurrence of the ED0 agreed with our report without substantive comment.
IE advised that they will utilize the report and the survey responses in on-going reviews of the inspection programs.
i
Attachment:
Subject Report cc:
W. Dircks, Acting EDO.
Heads of Offices G
G e
TABLE OF CONTENTS Pace s
INTRODUCTION-1 SCOPE OF REVIEW 2
PHILOSOPHICAL CONCEPTS OF THE NRC POWER REACTOR 2
INSPECTION PROGRAM
.n Accountability and Responsibility 3
Quality Assurance '
'3 Scope of IE Inspections Not Limited 4
BACKGROUND 4
Pre-Construction Permit Phase 5
Construction Phase 5
Preoperational Testing and Operational 5
Preparedness Phase Startup Testing Phase 5
Operations Phase 5
Decommissioning and Dismantling Phase 6
IE REACTOR INSPECTION PROGRAM STAFF 6
AUDIT FINDINGS AND OBSERVATIONS 8
INSPECTOR ONSITE TIME 8
Inspector Travel Time 9
Inspector Utilization 11
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Inspector Presence at Reactor Sites 12 INSPECTION DOCUMENTATION 14 Inspection Reports 14 Informal Documentation 15 t
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2 Page INSPECTION PERFORMANCE 16
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Scope of Inspection 16 Inspector-Licensee Relationship 17 INSPECTION FROGRAM PERFORMANCE 17 Status of Implementation 18 Inspection Phases
,19 Results of Reactor Inspections 21 Nonconfonnance With Provisions of 10 CFR 32 OIA INTERVIEWS WITH REACTOR LICENSEES 33 QUANTITY OF NRC INSPECTIONS 33 QUALITY OF INSPECTORS AND INSPECTIONS 36 COMMUNICATION WITH THE NRC 38 NRC INSPECTION REPORTS 39 INSPECTOR FEEDBACK 40 UNRESOLVED ITEMS 41 OIA SURVEY OF REACTOR INSPECTORS' VIEWS AND CONCERNS 41 UNIFORM IMPLEMENTATION OF REACTOR INSPECTION PROGRAM 41 INSPECTION REQUIREMENTS OF LITTLE OR NO VALUE 42 FLEXIBILITY OF INSPECTION PROGRAM 42 INDEPENDENT INSPECTION EFFORT 43 UNANNOUNCED INSPECTIONS 44 RESULTS OF ANN 0UNCED INSPECTIONS 45 APPROPRIATENESS OF UNANN0UNCED INSPECTION POLICY 45 l
ADEQUACY OF ENFORCEMENT MECHANISMS 46 l
3 Page
- QUALITY ASSURANCE. PROGRAM 47 ACTIONIT84TRACKINGSYSTEM(AITS) 47 RESPONSIVENESS OF TRAINING PROGRAMS 48 INSPECTOR EVALUATION OF LICENSING DOCUMENTS 48 UTILITY POLICIES AND PRACTICES DURING INSPECTIONS 49 SUPERVISORY CHANGES MADE TO INSPECTION FINDINGS 50 IE SUGGESTION PROGRAM 50
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MOBILITY. POLICY 50 CAREER LADDER 51 ADEQUACY OF OVERALL REACTOR INSPECTION PROGRAM 52 OTHER COMMENTS 52 4
O
INTRODUCTION One of the major functional activities of the fluclear Regulatory Commission (NRC) and its predecessor, the Atomic Energy Commission (AEC), is that of regulating the use of commercially owned nuclear power reactors.
This regulatory activity involves the developing of standards and regulatory guides, the licensing, and the inspection of commercial power reactors from inception through decommissioning. While the development of standards and licensing are major regulatory functions, the main focus of this report is on the NRC inspection activity at commercial nuclear power reactors.
NRC, through its Office of Inspection and Enforcement (IE) and five' regional
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offices located throughout the United States, perfonns inspections of reactor licensees to ascertain comoliance with NRC regulations, rules, orders, and license provisions. Our review was principally concerned with that part of the reactor inspection pecgram administered through IE Headquarters' Division of Reactor Construction Inspection and Division of Reactor Operations Inspec-tion. These divisions are responsible for the inspection of construction and operations activities at reactor sites. Although environmental, safeguards, and vendor inspections are also part'of the overall NRC reactor inspection program, the Office of Inspector and Auditor (0IA) did not examine these areas during our review. Also, although the NRC reactor inspection program includes research and other reactors, our review dealt mainly with that portion of the inspection program relating to commercial power reactors.
In order to help define inspection program and work load requirements. IE places reactors into " categories" based on phases in the nonnal life history of reactors or the type of reactor subject to NRC regulation and inspection.
The following is a summary showing the number of reactors, by category, as of August 1978:
Number of Ca teoory Description Reactors A0 Pre-Construction Pennit (Pre-CP) 39 Inspection Al Cons truction 65 A2 Pre-Operational Testing 78 81 Startup 4
B2 Initial Operations 12 C
Commercial Power Operations 57 D
Reactors During Extended Shutdown 1
D1 Deactivated Power Reactors 6
D2 Deactivated Non-Power Reactors 14 E
Research Reactors (High Power) 4 F
Research Reactors (Low Power) 29 G
Other Research Reactors and "Criticals" 24
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2 In perfoming our review of the PRC reactor inspection program, our primary objective was to assess the degree to which IE policies and procedures for inspecting commercial nuclear power reactors, as contained in the IE Manual, were being successfully implemented and, where applicable, recommend improvements in the reactor inspection program which would increase its efficiency and effectiveness.
SCOPE OF REVIEW Our review was perfomed during the period December 1976 through November 1977, at which time it was interrupted due to two high priority investigative assignments.
The results of our review are being issued as an infomation-type audit report because:
(1) considerable time has elapsed since the review was suspended;-(2) the General Accounting Office (GAO) has issued a report on the reactor-construction program, which included coverage of the same areas as the OIA review; and (3) it would be impractical to reactivate this assignment without duplicating work previously perfomed. An additional important consideration was the implementation of a revised inspection program by IE entailing the stationing of resident inspectors at several reactor sites beginning in late Fiscal Year (FY) 1978.
Also, the review work conducted by 0IA had not identi_fied serious deficiencies in the inspection program areas which we had examined.
Our review was conducted at NRC Headquarters and Regions I, III, IV, and V.
We examined pertinent inspection records and had discussions with regional directors and their staffs and with officials of IE Headquarters' Divisions of Reactor Construction Inspection and Reactor Operations Inspection.
As part of our review, we accompanied regional office reactor inspectors to observe the actual conduct of construction, operations, ard decommissioning inspections.
In addition, we conducted a survey of field inspectors in Regions I, III, IV, and V through the use of.a questionnaire and obtained the inspectors' views on the inspection program. We also met with upper management officials of 23 utilities to obtain their views and concerns regarding the NRC reactor inspection program.
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PHILOSOPHICAL CONCEPTS OF THE NRC POWER REACTOR INSPECTION PROGRAM The following " concepts" are part of the foundation on which the NRC reactor
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inspection program is built.
These " concepts" date back to AEC. While the reactor inspection program has undergone changes since the inception of NRC, the major foundational concepts have remained the same.
Understanding these
" concepts" is important in attempting to evaluate the implementation of this inspection program.
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3 Accountability and Responsibility.
One of the concepts of the IE inspection program is that the licensee is responsible for the construction and the safe operation of a nuclear power plant.
IE !!anual Chapter (f1C) 2500, " Reactor Inspection Program," states:
It is emphasized that it is the licensee's responsibility to construct and operate the facility safely and in compliance with construction pennit and license provisions and regulatory requirements..IE inspections are not designed to duplicate or substitute for a licensee's management controls established as a part of his quality verification system. Although IE may question the adequacy of the methodology used by the licensee, it is not an IE function to recommend modes of operation to the licensee unless such a mode is definitely established I
by a regulatory requirement.
Safety must be assured by the licensee, and 11RC holds the licensee accountable for safety and not the licensee's contractors, employees, consultants, or other third partiec. All IE inspection reports and enforcement correspondence are directed to the licensee (except in the case of the vendor inspection program). Thus, NRC licensees and licensee applicants must accept complete and total responsibility for facilities and operations licensed or to be licensed by NRC.
Quality Assurance Another basic NRC concept is that the key to the safe construction and operation of a nuclear reactor is for the licenseg to have an adequate, fully implemented quality assurance (QA) program.
Title 10 of the Code of Federal Regulations (CFR) Part 50.34 requires each applicant for a construction pennit (CP) to submit a Preliminary Safety Analysis ' Report 'which includes a description of the QA program to be applied to the design, fabrication, and testing, of the structures, systems, and components of the facili ty. Appendix B to 10 CFR 50.34 sets forth the requirements for QA programs for nuclear power plants.
10 CFR 50.34 (10)(b) requires each applicant for a license to include a Final Safety Analysis Report (FSAR) as a part of his operating license application and specifies matters that must be included in the FSAR.
While NRC's Office of Nuclear Reactor Regulation has the responsibility of reviewing and making the detennination regarding the acceptability of the QA program description presented in Safety Analysis Reports (SAR), IE is responsible for ascertaining that applicants have established and adequately implemented the QA programs described in the SARs.
The NRC inspection of QA activities is the topmost layer of many layers of QA functions. Additional layers include internal and external audits of QA by corporate-level utility organizations, plant-level organizations, architect /
engineering finns, construction contractors, subcontractors, and vendors.
The IE inspection program has the same elements as those of NRC licensee's and others, namely:
(1) audits of QA records; (2) inspection of completed
4 work; and (3) the observation of work being perfomed.
The follcwing illustration is intended to show that most of the QA effort for nuclear power plants is performed by contractors and licensees.
Consequently, the NRC inspection activities constitute an overview, or audit function, to assure that other QA programs are adequate and effective.
Scoce of IE Inscections Not Limited Although IE inspections are designed to determine whether NRC regulations (10 CFR), specific license conditions, industry standards, etc., are complied with, IE's inspection philosophy is that its inspectors are also responsible for identifying areas where a plant is potentially not being constructed or operated safely and regulatory requirements are inadequate, unenforceable, or lacking. Thus, through the identification of potential safety problems the inspection program is expected to improve the safety of nuclear reactors
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as well as correct weaknesses in NRC regulatory programs.
BACKGROUND IE's reactor inspection program is dynamic and is being refined and revised on a centinuing basis.
The inspection program is documented by separate programmatic chapters in the IE Manual for each of the several different types of reactors (i.e., light-water reactors, high-temperatura gas-cooled reactors, liquid-cetal fast breeder reactors, and test and research reactors and critical facilities). Detailed inspection procedures are contained in procedural subchapters (inspection modules) and are structured or organized on a technology or inspection skill basis.
For example, there are inspection modules for the inspection of training, excavation and earthwork, structural steel, piping, welding, physical security, radiattori protection, etc. There are currently more than 400 inspection modules applicable to light-water power reactors.
Inspection modules are organized into three sections.
t An " objectives" section contains short statements on the objectives of the
' inspection module. A " requirements" section cMains the detailed inspection procedures which are to be performed by the int actor. A " guidance" section contains instructions and directions to amplify or explain inspection require-ments. The " objectives" sections are less than a page in length while the
" requirements" sections are frequently four or more pages in length and may include 50 or more inspection steps (line items).
" Guidance" sections are also often lengthy, may reference specific provisions of FSARs,10 CFR, regulatory guides, etc., and may also state the size of samples or extent of tests to be perfomed to satisfy an inspection requirement.
The light-water reactor (LWR) inspection program (which accounts for most commercial nuclear power reactors) is divided into six discrete phases of inspection activity covering the entire life span of a power reactor.
It should be recognized, however, that the inscection requirements within one phase are freauently performed concurrently with the inspection reouirements of another phase.
The inspection requirements for the six phases of inspection activity are set forth in IE 11C 2511 through MC 2516 as follows:
m
5 MC-2511 LWR Inspection Program - Pre-CP Phase MC-2512 LUR Inspection-Progran '- Construction Phase MC-2513 LWR Inspection Program - Preoperational Testing and Operational Preparedness Phase MC-2514 LWR Inspection Program - Startup Phase MC-2515 LUR Inspection Program - Operations Phase MC-2516 LWR Inspection Program - Decommissioning and Dismantling Phase Pre-Construction Pennit Phase The inspection program for this phase includes as many as 26 different inspection modules, some of which may be required to be accomplished more than once. The inspection activity may be initiated as early as six to y
twelve months prior to a licensee's tendering of an application and extend to, or beyond, Advisory Committee on Reactor Safeguards (ACRS), Atomic Safety and Licensing Board Panel, and/or Atomic Safety and Licensing Appeal Panel hearings and may overlap inspections conducted under the construction phase.
Construction Phase The IE inspection program for the construction phase of a reactor may include as many as 88 inspection modules to be accomplished beginning as early as six nonths before a CP or limited work authorization is issued and extend to the issuance of an operating license.
Preoperational Testing and Operational Preparedness Phase The preoperational inspection program may include as many as 110 gener'al inspection modules plus 27. modules applicable to boiling water reactors or 32 modules applicable to pressurized water reactors.
Inspections under this phase may begin as much as eighteen months prior to the projected issuance of an operating license and overlap both the construction phase and startup phase.
Startup Testing Phase The startup inspection program begins six months prior to the issuance of an operating license and extends until a month after the reactor attains full commercial power operations. This phase includes 17 general inspection modules and 28 modules for bailing water reactors or 26 modules for pressurized water reactors.
Ooerations Phase The operations inspection program begins when an operating license or a fuel ioading authorization is issued and extends over the estimated 40-year
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operating life of a reactor. The program includes about 80 inspection
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. modules, some of which are required to be conpleted quarterly, annually, every three years, each refueling, when an event occurs, when required by the guidance section of the module, as scheduled by the licensee or Technical Specifications (Tech. Specs.), each inspection, etc.
Cecommissioning and' Dismantling phase Th' IE !!anual does not yet include procedures for this phase.
e IE REACTOR INSPECTION PROGRAll STAFF
-The IE reactor construction and operations inspection programs are administered at both the Headquarters and regional levels.
At the Headquarters level (Figure 1) the Civisionc of Reactor Construction Inspection and Reactor
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Operations Inspection develop, publish and revise the inspection program, provide management and technical support to the regions, nonitor the regional inspection activities, and perform other activities related to performance of the inspection program.
Each division is neaded by a director, who reports to the Director, IE.
FIGURE 1 IE HEAD 0VARTERS ORGANIZATION Director, IE c
Div. of Reactor Div. of Reactor Construction Operation Inspection Inspection At the regional level, the reactor inspection program is implemented through the Reactor Operations and Nuclear Support Branches and the Reactor Construction and Engineering Support Branches (Figure 2).
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7 FIGURE 2 REGI0flAL OFFICE OPGAtlIZATI0ff Regional Director fluclear Support ll Reactor Ops. &
l Reactor Const. &
,Eng. Support Branch Branch I
i lProjectSection
, Support Section Project Section Support Section These branches, usually consisting of one or more project sections and one or more support sections, are responsible for the routine day-to-day performance of the inspection program. The projects section contains the project (or principal) inspectors who are assigned the overall responsibility for the conduct of the prescribed inspection program (construction or operations).
In perfoming these duties, the project inspector is usually assigned one or core facilities and plans, coordinates, and usually helps perfom inspections while acting as the primary flRC contact for the licensee.
The project inspector is required to have a general knowledge of the reactor facility and the utility's operations.
The support c :tions contain the specialist inspectors who have a proficiency in one or more specialized areas and plan and perfom in-depth inspections of designated specialty areas. Generally, the specialist inspector has a high degree of specialized knowledge in one inspection areas and performs hh inspection assignments at all the or mor::
applicable reactor sites in the region.
The following chart shows the staffing of the reactor inspection program as of August 31, 1978:
REACTOR INSPECTION PROGRAM STAFFING 8/31/78 Division of Division of Reactor Reactor Reactor Reactor Operations Construction Construction Operations and fluclear and Engineering Inspection Inspection Support Br.
Support Br.
Headquarters 10 21 Region I 26 26 II 42 29 III 30 26 IV 11 11 V
12 13
8 Note: All figures include division directors, branch chiefs, and section chiefs but do not include interns or co-op students.
It is OIA's impression that the IE reactor inspection staff is well qualified by education and experience and, in our opinion, is technically competent to carry out the reactor inspection program.
Our survey disclosed that a great many of the inspectors and supervisors were at one time licensed as AEC/NRC reactor operators or senior reactor operators or were experienced reactor operators of Navy or other military and Government-owned reactors before being employed t,y NRC. Most of the inspectors have undert,.aduate or graduate degrees in engineering or other sciences. We understand that it has only been within about the last two years that new college graduates without extensive work experience have been employed by NRC to be reactor inspector interns.
Thus, for
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the most part the field inspection staff is composed of mature individuals with many years of experience in fields of construction, engineering, and industrial process.
It should also be noted that IE rear:or inspectors cust attend NRC-sponsored training courses and satisfactorily complete a written examination at the conclusion of each course in order to be considered qualified to inspect at reactor sites.
IE has a rather extensive in-house training program directed principally toward providing general and specialized training to inspectors who conduct inspections at nuclear power reactor facilities. A recent catalog listed 33 courses for reactor inspectors, 14 courses for safeguards inspectors, and 3 for health physics inspectors.
Sbme of the IE inspector training is provided at commercial training facilities. The lengths of the courses are from three days to four weeks.
In addition, in-house training is provided in the several regional offices by the regional inspection staff.
AUDIT FINDINGS AND OBSERVATIONS INSPECTOR ONSITE TIME One of the areas receiving a considerable amount of attention by NRC managenent is that of inspector "onsite" time.
"Onsite" is an ambiguous tem. The tem has been used by IE to refer to the percentage of paid hours that inspectors are at a licensed facility perfoming inspections.
The term has also been used to refer to the total number of hours that inspectors are at a facility during a pe,riod of time, typically one year. Critics of the NRC inspection program usually intend the second meaning when they contend that NRC inspectors do not spend enough "onsite" time to adequately assure the safe operation and construction of nuclear power reactors.
In a report titled "The Nuclear Regulatory Commission Needs To Aggressively Monitor and Independently Evaluate Nuclear Power Plant Construction," dated September 1978, GA0 recommended that NRC
" increase the time the inspectors spend perfoming inspection work at construction sites."
9 IE internal quarterly management reports (since discontinued) showed for each region how the inspection staff time was being expended.
The following analysis taken from the quarterly reports shows how the construction inspectors reported their time for two quarters in Calendar Year (CY) 1978.
Onsite Inspection Effort 23.4%
21.5%
Offsite Inspection Effort 1.4%
l.0%
In-Office Inspection Effort 2.5%
2.9%
Travel 12.5%
11.9%
Preparation and Reporting 45.5%
40.9%
Headquarters Projects 1.9%
2.0%
General Program Effort 7.7%
7.6%
TOTAL PROGRAM TIME 95.1%
88.1%
TOTAL NON-PROGRAM TIME 16.6%
21.3%
111.7%
109.4%
Over the last few years, IE management has closely scrutinized inspectors "onsite" time statistics.
In a memorandum dated June 8,1978, the Director, IE, set a perfomance goal of 27 percent "onsite" time for all reactor inspectors.
IE management officials have also indicated that the implementation of the resident inspection program will increase the anount of "onsite" time achieved by the reactor inspection program, although specific increased figures cannot be supplied.
Insoector Travel Time Under the current flRC arrangement, inspectors travel from the five regional offices to reactor sites located within each region.
Inspectors incur travel time on each inspection trip, which IE management records separately from that of "onsite" time. Therefore, the amount of travel time necessary to reach a reactor site has a direct impact on the amount of "onsite" time available.
As part of our audit review, we sent questionnaires to each of the regional offices requesting typical travel data for each rcactor site
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within a region. The travel data requested included the amount of travel time to and from the regional office and reactor site, distance between lodging and site, modes of transportation, and arrival and decarture tires of the inspectors. We analyzed responses from two of the five regions, which we believe were representative of the travel requirements of the flRC regions.
Our analysis shews that the average amount of time spent traveling to and from a reactor site is four to four-and-a-half hours each way (Table 1).
This means, that on the average, each time an inspector visits a reactor site, more than eight hours of his time away from the regional office is unproductive or lost time.
IE cuarterly reports indicate that travel time accounts for about one-third of the time reactor inspectors are on
10 duty and away from their regional offices.
In scce instances, the acount of travel time needed to reach a reactor site is in excess of
.eight hours cach way.
In such cases, assuming that an inspector leaves for a reactor site on Monday and returns home on Friday, only Tuesday, Wednesday,-and Thursday are available for actual inspection effort.*
TABLE 1 AVERAGE TRAVEL TI!1E-TO AND FROM REACTOR SITES Average Travel Time Average Travel Time to Site from Region to Region from Site Region A 4.54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> 4.65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> Region B 4.06 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 3.93 hours0.00108 days <br />0.0258 hours <br />1.537698e-4 weeks <br />3.53865e-5 months <br /> A related statistic to that of travel time is the distance from the region to the reactor site, which has a direct bearing on how long it takes to travel to a reactor site.
Table 2 shcws.that the average distance from regional office to reactor site is 462.18 miles in Region A and 212.00 miles in Region B, a difference of 250 miles. However, the travel time it takes to get to a reactor site in Region B is not significantly different from that of Region A.
This is crincipally due to the fact that the reactor sites in Region B are scmaahat isolated and difficult to reach, with most inspectors traveling by car to a large ' number of the sitas.
TABLE 2 AVERAGE DISTANCE TO REALTOR SITES Region Average Distance to Site Region A 462.18 miles Region B 212.00 miles "via reuna tnat in actual practice, i*onday mornings are of ten reserved for regional staff meetincs and training sessions.
Therefore, inspectors usuall do not leave untif Tuesday morning.
3 D
11 Our survey also included rodes of transportation used by the inspectors in traveling to reactor sites and the distance between lodging and the reactor sites (Tables 3 and 4 show the results of-our survey). Privately owned mutemobiles (P0A), Governrrent vehicles (GV), airplanes, and rental cars ( C) are the most frequently used nodes of transportation. Automobiles (rental, P0A, or General Services Administration [GSA] motor pool) are the most frequent conveyance used in commuting between lodging and reactor sites. The average distance from lodging to reactor site is 21 to 30 miles, with a distance in excess of 40 miles at several reactor locatf or s.
TABLE 3
!10 DES OF TRAVEL P0A Taxi GV Limo Air RC GSA Region A 11 4
1 3
10 10 7
Region B 22 0
22 15 16 22 22 TABLE 4 AVERAGE DISTANCE LCDGING TO SITE (in miles) 0-10 11-20 21 -30 31-40 41+
Region A 2
3 3
1 2
Region B 6
2 7
3 1
Our survey revealed that in an attempt to achieve more "onsite" time the inspectors routinely start their travel time prior to the beginning of nomal working hours and return home af ter the conclusion of the working day. Assuming nonnal working hours to be 8:15 a.m. to 5:00 p.m., on the average, the inspectors leave 1.30 to 1.50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> prior to the start of the normal workday and return home 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the conclusion of the workday.
Inspectors are rarely compensated by NRC for this additional time because they are considered to be professional employees who need not be paid for overtime except under special circumstances lsee discussion which follows).
Inspector Utili:ation In an effert to increase inspet: tor "onsite" time, IE management routinely examines the allocation of inspectors' time.
In the IE quarterly report for the period ending August 31,1978, "onsite" time for reactor construction inspectors averaged 21.5 percent of regular hours for the five regions, l
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12 a range of 15.1 percent to 24.0 percent reported.
It should be noted that all of the regions reported greater than 100 percent of regular man-heurs available for construction inspectors, with an average of 109.4 percent of regular hours reported by the inspectors.* For the reactor operations inspectors, the average "onsite" time was 25.5 percent, with a range of 22.0 percent to 29.9 percent. Reactor operations inspectors reported a total of 110.6 percent of regular hours for the quarter ending August 31, 1978.
It is interesting that the 9.4 percent and 10.6 percent excess of regular hours reported by construction and operations inspectors is nearly equivalent to the percentage of time the inspectors spend in travel status prior to or after normal working hours.
IE management believes that the implementation of the resident inspection program will improve inspector "onsite" time and promote improved inspector efficiency.
Inspector Presence at Reactor Sites As part of our audit work, OIA analyzed and scheduled inspector "onsite" time statistics for CY 1976. We scheduled the onsite time spent at each facility, by month, listing each inspector that visited the site.
The results of our analyses show that the typical reactor site receives widespread coverage throughout most of the calendar year.
The results indicate that it is unusual when a reactor site is. not visited by an NRC inspector at least once a month.
In some instances, it is not uncommon to have several inspectors at a reactor site at different times during the month.
It is difficult to draw conclusions based on the data as each reactor site is somewhat different, and, therefore, a homogeneous universe does not exist.
Time spent at reactor construction sites will vary depending on the percent, age of completion of the reactor, the construction schedule, the amount of safety-related work being parformed, etc.
Basically, because a large part of the reactor construction inspection program involves observation of work activities, the more safety-related construction activities that are being perfomed at a reactor site will involve a corresponding increased amount of inspection effort. The same situation exists for reactors in the preoperational phase. As the licensee detennines and implements the reactor testing schedule, NRC inspection coverage has to conform and adjust to meet the licensee's schedule.
As in construction inspections, preoperational inspections do not necessarily flow evenly through a period of time but, rather, may be concentrated during short intervals of time. We were informed by IE personnel that as a reactor approaches fuel loading (and an operating license), the frequency of inspection increases significantly.
- lt is possible to achieve greater than 100 percent of available man-hours due to the uncompensated overtime put in by the inspectors.
In this case, the average 9.4 percent excess of available man-hours closely correlates to the travel time spent by inspectors outside of normal working hours.
13 Due to the cyclical nature of the reactor operations inspection program, inspections can usually be perfomed on a somewhat even basi.- throughout the year.
It was 01A's inpression that operating reactors received a fairly steady inspection coveraga spread throughout the year. We noted that for operating reactors, it was unusual for some flRC inspectors not to be at the reactor site at least once a month.
Because operating reactors also receive safeguards, health physics, fire protection, and other inspections throughout the year, teams of NRC inspectors usually are at these sites one or more times per month.
He believe the establishment of numerical goals for "onsite" time for inspection by the IE Director may cause inspectors to visit reactor sites more frequently than the minimum needed to accomplish the required inspection program.
As noted earlier, it has been argued by critics of the ilRC inspection program that the inspectors do not spend enough time "onsite" at reactor locations. Based on our review, 0IA believes that any shortage of "onsite" time by any inspector or group of inspectors is, at least partially, offset by the repetitive and almost continual inspection coverage that reactor sites receive from the overall IE inspection program. We were not able to detemine what objective criteria would be ap::repriate for establishing what an adecuate amount of "ensite" inspection tine should be for a power reactor. The critics, to our knowledge, have not stated what they consider would be adequate tiRC inspector "onsite" time.
OIA believes it is important to recognize "onsite" time involves two different issues: (1) the portion of an individual inspector's time which would be spent at tiRC-licensed facilities; and (2) the amount of total inspection "onsite" time to which a licensed facility should be exposed. He believe that individual's "onsite" time is necessarily limited by the amount of time away from home the inspection staff will tolerate as well as the amount of in-office time required to support the inspection program.
It appeared from an earlier 0IA survey of IE materials inspectors that the inspection staff would tolerate a maximum of about 40 percent time away from home. On this basis, an IE program goal of 30 percer.t "onsite" time for reactor inspectors would seem reasonable considering the indicated average travel time to and from reactor sites.
The assignment of resident inspectors is expected to increase the total "onsite" time at the sites assigned such residents.
As a result of our review, we reached no conclusions as to whether any minimum amount of
~
"onsite" time should be expended at each licensed reactor facility or whether inadequate or excessive "onsite" time was being expended. We did, however, observe that operating power reactors were inspected very frequently and at all hours, such that licensees cannot be assured that an fiRC inspector may not appear at any time in any 24-hour period.
Some licensee officials appear to regard the NRC inspection program as virtually continuous and regard the presence of one or more inspectors "onsite" as a nonnal and not unusual condition.
gogm py L
M o i l l ir L
14 INSPECTION DOCUMENTATION Our review showed that there are two systems of inspection documentation employed by NRC inspectors. One fom of documentation is the official NRC inspection report which is issued subsequent to the conclusion of an inspection. The other existing foms of inspection documentation are the notes, charts, etc., kept by the individual inspectors allowing them to track the perfomance of individual module inspection procedures.
These two documentation systems, one fomal and one infomal constitute the material available to substantiate the inspection work perfomed.
Inspection Reports NRC reactor inspections are documented in official NRC reactor inspection reports, which are issued by the regional offices.
The reports are sent to the licensees and, after review for proprietary infomation, are also sent to the Public Document Room (PDR).
The purpose of the reports, and the amount of documentation to be contained in NRC inspection reports, is delineated in IE MC 1005, " Inspection Reports." MC 1005 states that "the basic policy is to provide a written record of inspections" and further states that the purposes of the inspection report are to:
"(1) provide a basis for enforcement action and convey the results of the inspection to the licensee or v'endor; and (2) provide infomation for management of the inspection program within the Office of Inspection and Enforcement.
Secondary purpo:,es are to provide infomation to other NRC offices and to the general public."
The manual chapter delineates the items that are to be contained in official IE inspection reports.
Items to be contained in an inspection report include an inspection summary, noncompliance items and deviations, unresolved items, and functional areas inspected. Other items included in the inspection reports are the inspectors perfoming the inspections, scope of inspection, persons contacted, and summaries of entrance and exit conferences. A standard fomat cover sheet to the inspection report is also contained in MC 1005.
The standard cover sheet includes the inspection report number, date of inspection, licensee and facility name, inspectors, supervisor's approval and an inspection summary.
As part of our audit work, we reviewed reactor inspection reports in each of the four regions visited. Our review indicated that, generally, the regions are preparirg their inspection reports'in accordance with the criteria centained in tic 1005.
While we were not able to discern the specific modules (or module procedures) perfomed during an inspection, this infomation is not required by i1C 1005 to be included in the inspection report. However, inspectors do report the percentage completion of modules at the completion of each inspection. The status of inspection modules applicable to each NRC reactor license can be obtained from the IE management infomation system computer file.
l
15 Infomal Docurentation The-second system of documenting reactor insoections consists of the notes, checklists, grid schedules, etc., that are kept by regional in>pectors.
This system of documentation, which is not required by IE MC 1005, allows the inspectors to track the individual inspection line items that are contained in the inspection modules.
In this way, the inspectors can detemine the status of the inspection program as it relates to each plant for which they have inspection responsibilities.
As part of our audit work, we reviewed this infomal documentation for both reactor construction and reactor operatians inspections. With respect to construction activities, we found that the inspectors generally kept well organized notes, schedules, checklists, etc., indicating the status of the inspection activities.
This is necessitated by the fact that construction-related inspection modules are usually not completed in one inspection but, rather, remain open for an indeteminate period of time until they can be completed. We learned that the way construction inspection modules are organized requires the inspectors to keep somewhat-voluninous inspection records. We received varying complaints from insrectors that this increased paperwork load had a detrimental effort en their inspection cutput. OIA noted that the inspection docueentation
'or c:nstruction activities was sometimes very voluminous, with tuo or three notebooks being used to keep track of module "line items." OIA also noted a lack of unifomity in the types and amount of documentation kept by the inspectors. Not only was documentation not unifom between regional offices, but in several instances documentation was not unifom within the same region. This seemed to cause some problems when principal inspector assignments were changed from one inspector to another, as the inspectors had to explain to each other how their record-keeping systems worked. Three of the four regions visited used a standardized system of documentation within the reg (ion, and two of these three regions used similar systems to document or track) the completion of the reactor construction inspection program.
With respect to the reactor operations inspection program, similar conditions were found to exist. Documentation of inspection module procedures did not appear to be as good, or as well organized, as that found with respect to the reactor construction program.
In some cases it was difficult, if not impossible, for us to determine the status of the operations inspection program by reviewing the inspectors' personal tracking notes or schedules.
Lack of documentation was probably caused by the fact that, in certain instances, operations inspection modules can be completely performed on one inspection. Therefore, the inspectors may not need an elaborate tracking system to remember incomplete inspection nodules. We also found the operations inspection documentation to be nonunifom both between regions and within regions. Documentation maintained by inspectors varied from none to elaborate schedules detailing the planning and completion of inspection modules.
l 8
16 While we are not now reco: mending fomalizing the documentation requirements and recording the completion of each step in each inspection module, we believe that the development of a unifom system for documenting inspection work perfomed, or not perfomed, would be generally beneficial and would enhance the credibility of the program.
In cases where, as is pemitted by the IE l'anual, inspection modules are closed at less than 100 percent completion of all required line item steps, it could be important for IE management to be able to detemine with a high degree of certainty at some later date what was or was not accomplished. The adoption of a standardized documentation system would, we believe, improve the efficiency of the regional office operations and their ability to track the inspection program.
~~
The resident inspection program would seem to require that the regions maintain more detailed inspection documentation records. We suggest that IE study whether the inspection nodules could be configured to be compatible with a computer program which would account for and serve as the semanent record showing the completion or noncompletion of inspection module "line item" requirements.
INSPECTION PERFORMAtlCE As part of our audit, we accompanied regional inspectors on 18 inspections.
These included construction, test and startup, preoperational, operations, and decommissioning inspections. We observed the perfomance of numerous inspection modules, which we believe provided an adequate cross section of the reactor inspection program. We traveled with the inspectors, stayed in the same motels, and generally tried to acclimate ourselves to the routines followed by NRC inspectors.
Secpe of Inspection While observing the conduct of inspections, OIA was impressed by the breadth and depth of the inspections perfomed by the NRC inspectors.
The inspectors did not limit themselves to perfoming just the inspection modules selected for that inspection but were also observant of other areas where problems might occur. On all the inspections we observed, the inspectors at some time during the inspection took an extensive tour of the facility.
The inspectors used this facility tour to examine areas of the plant other than those covered by the inspection modules to be perfomed. He noted that several items of nonccmpliance, or open items, were found during these plant tours.
The inspectors appeared to us to always be alert to construction or operating defects while on their plant tour. Although licensee personnel accompanied the inspectors, we did not have the impression that these personnel influenced or detemined where or what the inspectors looked at.
17 Over the years, various criticism has been raised that, while conducting inspections, the NRC inspectors review too much paperwork and do not observe enough construction activity. OIA did not get this impression on the inspections we observed. While the inspectors did review paperwork to help substantiate direct observation of work activities, we found the majority of an inspection to involve observation of the site and work activities. The inspectors generally commented that they would rather be out in the plant than in a room all day reviewing records.
In fact, on several of the inspections we observed, the inspectors returned to the site during off-shift hours to observe the perfomance of construction or operations activities.
Overall, what impressed us most was that the inspectors did much more during an inspection than just perfom inspection modules.
In fact, the inspectors seemed to always be on the lookout for any condition that could affect the safe construction or operation of a nuclear plet.
Inscector-Licensee Relationship During the perfomance of an inspection, we were able to observe the interaction between inspectors and licensee personnel.
In most cases we were pleasantly surprised to find professional, yet casual, rapport between the inspectors and the licensee instead of the fomalized and structured communication channel we had anticipated. There seemed to be a genuine professional respect between licensee personnel and the inspectors, which helped facilitate the conduct of the inspections.
In a few instances, we nottd some communication problems between the inspectors and licensee personnel. However, these problems appeared to be a resu't of differing personalities, which cannot be totally avoided. Our disci.ssions with licensee site personnel indicated they considered most NRC inspectors to be technically competent in the areas inspected, and this helped when problems or safety issues had to be discussed.
We also noted during our inspections that the inspectors tended to keep site personnel aware cf the areas being inspected and any problems that were being encountered. The licensees told us they appreciated this, as it allowed them to put inspectors in touch with the appropriate personnel necessary to resolve any problems. This advance communication also assured that no " surprises" were brought up at the exit conferences, which in some cases were attended by one or more members of a licensee's upper management.
INSPECTION PROGRAM PERFORMANCE In order to better evaluate the perfomance of the IE reactor inspection program, 0IA obtained pertinent inspection program statistics and other data frcm the IE management infomation system (ti!S) computer file.
Infomation is submitted into the MIS through the use of NRC Fom-766, which is completed by the inspector at the conclusion of an inspection.
We requested and evaluated infomation pertaining to inspector man-hours, number of inspections, noncompliance citations, and other data related to the inspecticn program.
18 Status of Implementation One of the major objectives of our review was to detemine the status-of implementation of the reactor inspection program. As certain perfomance time frames are built into the inspection program, we wanted to ascertain whether inspections were being perfomed on, ahead of, or behind schedule.
In the construction and preoperational phases, detemination of program status was difficult, if not virtually impossible.
In the operations phase, detemination of program implementation was easier and much more reliable.
A large part of the reactor construction inspection program involves the observation of work activities as the plant is being built.
In many cases, this involves observing work that will only be performed once during the construction of a plant.
Construction schedules are set by e
the licensee. Therefore, IE must adjust its inspection schedules accordingly to enable IE inspectors to observe construction work as it is perfomed at the site.
It is incumbent on principal inspectors and regional management to keep infomed as to the progress of construction in order to assure that inspectors observe work as it is being performed. As NRC implements its inspection program to meet the licensee's construction schedule, it was virtually incossible for us to detemine if inspection modules had been perfomed at the appropriate time.
If a licensee's construction schedule changes, an inspection module that would appear to be overdue might actually be unable to be performed. The same situation holds true for preoperational testing, which is scheduled by the licensee but must be followed by the NRC inspectors. Thus, to a large extent some phases of the construction inspection program are dictated by events beyond the control of IE, rather than by the provisions of the IE Manual as to the time inspections should nomally be expected to be perfomed.
From discussions with regional management and review of available inspection records, we tried to ascertain the status of implementation of the reactor construction and preoperational test inspection programs.
Regional managers indicated that no meaningful measurement tool existed for them to detemine the status of the inspection programs. Of the four regions we visited, three regions indicated that they were one to three months behind schedule with construction inspections, while one region indicated they were current with their inspection responsibilities.
One branch chief estimated that his branch 'was three months behind in the construction inspection program. To counteract this situation, the inspectors were told to perfonn the " observation of work" modules, as required, tnd when necessary to delay the " review of records" modules.
A review of regional office inspection records failed to provide an adequate veoicle with which to ascertain the status of the inspection program.
The refore, we had to rely on regional management's judgment concerning the status of the construction and preoperational test inspection programs.
The reactor operations inspection program was easier to evaluate and provided more accurate results.
Inspection modules cre perfomed on a more cyclical basis (usually every 12 to 18 months).
For licensees with good cmpliance records, the regional office can extend the inspection intervals for certain aspects of the inspection program. Discussions
T 19 with regional management and a review of inspection records indicated tnat operations inspection program modules appeared to have been accomplished on a timely basis. We found inspection modules perfomed as required by MC 2515, including, where appropriate, the extension of inspection intervals. Generally, with respect to the status of implementation of
-the reactor construction, preoperational, and operations inspection programs, we believe the programs were being satisfactorily implemented on a timely basis at the time we conducted our field work. When implementation delays did occur, these did not appear to have had any significant adverse effect on the programs perfomance.
It should be noted that as part of an internal self-study, IE has sent numerous study projects out to the regional offices to be accomplished.
Regional officials infomed us that this increased work load was straining their manpower resources and could ultimately have an adverse impact on the perfomance of the lutine inspec: fon program.
IE Headquarters officials indicated they were aware of the regional offices' concerns, and these officials infomed us that special Headquarters assignments were intended to take precedence over the routine inspection program.
Insoection phases IE classifies reactors according to' the stages in the nomal life cycle of reactors, and accordingly, has devised portions of the inspection program to be applicable to each such " phase." The following are the names of the various " phases" which describe reactor facility stages and the applicable inspection program " phases."
Pre-Construction Pemit; Construction Pemit; Preoperational; Test and Startup; Operations; Decommissioning; and Major Modification Work.
Table 5 shows the number of inspection man-hours attributed to each reactor phase and the number of inspection modules completed during CY 1976, CY 1977, and CY 1978.
The table reflects the decline in new applications for power reactors l
since 1976 by the decrease in inspection hours devoted to pre-construction pemit activities.
The table also shows an apparent increasing percentage of the total inspection effort has been applied to construction activities.
This is partially attributable to the large number of reactors being constructed, approximately 90, at the end of 1978.
It may be noted that the amount of attention given operating reactors remained almost the same in CY 1977 and CY 1978. Generally, it appears the data is consistent with the philosophy that inspection resources should be applied commensurate with the nuclear safety hazards. Thus, about two-thirds of reactor inspection man-hours were applied to reactors in after fuel loading phases and about one-third to the pre-construction pemit and construction pemit phases.
p 90@d 3
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TABLE 5 REACTOR INSPECTION t1AN-1100RS AND INSPECTION H0DULES PERFORf1ED CY 1976 CY 1977 CY 1978 MAN-MODULES MAN-110DULES MAN-110DilLES REACTOR PilASE 1100RS PERFORMED ll00RS PERFOR!!ED HOURS PERFORMED
~
Pre-Construction Permit 2,055 254 1,282 259 793 123 Construction Permit 19,936 3,679 25,489 5,340 30,712 6,430 Preoperational 9,834 1,353 9,671 1,305 7,761 1,046 Test and Startup 3,469 472 2,772 490 2,552 350
,o Operations 46,751 6,974 57,934 10,273 57,885 10,120 c)
Deconunissioning 14 2
tiajor Modifications 198 60 82,045 12,732 97,148 17,667 99,915 18,131 Dummy Modules
- 2,275 69 TOTALS 82,045 12,732 97,148 17,667 102.190 18,200
- Dummy Modules are used for recording inspection efforts not otlierwise covered by a specific inspection procedure such as obnormal occurrences, investigations, etc.
r 21 We converted the above data to man-hours per module as follows:
TABLE 6 AVERAGE Matt-HOURS PER IfiSPECT:1rl MODULE PERFORMED P.EACTOR PHASE CY 1976 CY 1977 CY 1978 Pre-Construction Pennit 8.09 4.95 6.45 Construction Permit 5.42 4.77 4.78 Preoperational 7.27 7.41 7.42 Test and Startup 7.35 5.66 7.29 Operations 6.70 5.64 5.72 7.00 Decommissioning 3.30 Major Modifications 6.44 5.50 5.51 32.97 Dummy "odules OVERALL AVERAGE 6.44 5.50 5.61 The average number of man-hours per module for most phases shows that the results were about the same in each year. The data for 1977 and 1978 appears very consistent and may reflect that the modular inspection programs for most phases were little changed during this two-year period.
Results of Reactor Insoections IE classifies inspections as " clear" if no items of noncompliance with 10 CFR are disclosed and "not clear" if one or more items of noncompliance are found. tioncompliances are classified into three orders of severity according to their relative safety significanca. The most severe noncompliance items are temed " violations," the next most severe items are " infractions," and the least severe items are called " deficiencies." For assessing the significance of an inspection, action point values of 100,10, and 1 are considered appropriate by IE for each violation, infraction, and deficiency respectively. When, as a result of an inspection, the total action points exceeds 100, regional offices must consider imposing civil monetary penalties on the subject licensee.
In addition to the three types of noncompliance findings assigned action points, IE inspections identify other findings as " deviations" and " unresolved" items. A deviation is a failure to confom to a commitment to the flRC to the provisions of guides, codes, or standards or to industry practices which have safety significance but is not considered to be noncompliance with 10 CFR. An unresolved item is a matter about which more infomation is needed in order to detemine whether it is a noncompliance, a deviation, or. is neither.of these and is acceptable confomance with regulatory requirements.
22 IE issues a " notice of violation" for noncompliance items found during an inspection to which the licensee must respond.
Licensees are also expected to respond to deviations and unresolved items which are identified in inspection reports.
Although IE regional practices are not unifonn, inspection reports sometimes cover all of the inspection work perfomed during a visit to a reactor site by one or more inspectors, or inspection reports may cover all of the inspection activity perfomed during several visits to a site over a period of several weeks. According to the IE !!anual, one inspection report may cover as much as all of the inspection work perfomed during a month's period. Thus, an inspection report may cover as little as a portion of only one inspection nodule by one inspector on one visit or the inspection effort applicable to one or more inspections at the same site for an entire month. An inspection is usually referred to as the period of_ a continuous visit to a site, and may or may not be the same as the inspection activity covered in an inspection report.
Therefore, the number of inspection reports is not indicative of the inspection effort perfomed; and thus, the number of " clear" and "not-clear" inspection reports have little significance. However, the percentage of times a module or group of modules is perfomed with "not-clear" results may be significant because it may be indicative of licensee performance by certain licensees, related groups of licensees or the industry generally.
We examined IE inspection data taken from IE's MIS to ascertain the extent to which inspection phases, inspection module series, and individual inspection modules resulted in noncompliance findings.
Table 7 summarizes the results of the reactor inspection progre.m. by reactor inspection phase, for the three-year period ending June 1978.
OIA believes the relative higher percentage of "not-clear" inspection modules (14.2 percent) for the operations phase may be indicative that more inspection effort should be applieo during the earlier construction permit, preoperational and test and startup inspection phases, particularly during the period immediately prior to and following the issuance of operating licenses. We believe more emphasis during this period should decrease noncompliance findings after reactors become fully operational.
Table 8 analyzes the inspection results, by inspection module series, to show the functional areas inspected, number of inspection modules perfomed, and the percentage of modules resulting in noncompliance. Table 9 is an analysis of non modulized inspections for which " dummy" modules are prescribed.
I
23 TABLE 7
SUMMARY
OF REACTOR INSPECTION PROGRAM RESULTS THREE YEARS ENDED JUNE 1978 r
Number of Different Total Number Number of Inspection of Times All Entrance / Exit Reactor Inspection Modules Modules Percent Inspection Phase Performed Completed Not Clear Interviews Pre-Construction 23 497 1.4%
159 Permi t Construction Permit 121 7,706 6.7%
1,436 Preoperational 133 2,927 2.4%
439 Test and Startup 81 946 5.0%
129 Operations 186 15,714 14.2%
3,215 TOTAL 449 27,790 10.4%
5,?78 Non-Modularized 19 545 39.1% Inspections
- GRAND TOTAL 468 28,335 10.9%
5,378
- Non-Modularizet Inspections are non-standardi:ed unique inspections for which uniform proceduras are not prescribed in the IE inspectic....anual.
The manual provides for the reporting of such inspections under several generic " dummy" inspection modules.
5 r,
TABLE 8 SUMtTARY OF IE kEACTOR INSPECTION PROGRAM RESULTS TilREE YEARS ENDED JUNE 1978 Number of Number of Percent of Different Times Modules Reactor Inspection Modules Modules Not-Clear Modular Series Inspection Functional Area Performed Perfonned Inspection 25XXX Temporary Reactor Inspection Procedures 8
147 2.0 30XXX IE/ Utility Corporate Management Meetings 7
197 1.5 35XXX Quality Assurance Activities 49 1,176 6.9 36XXX Qperational Staffing, Organization &
2 192 7.3 Administration g-37XXX Design, Changes, Modifications, Design Control 3
211 22.3 38XXX Procurement Activities 1
147 21.1 39XXX Records and Document Control and Storage 4
240 15.0 40XXX Safety Committee, Reviews and Audits 3
275 21.5 41XXy Operating Staff Training 4
332
-19.6 42XXX Procedures 8
562 13.5 45XXX Site Preparation 6
412
.7 46XXX Foundations (Construction) 3 218 6.0 47XXX Containment--Concrete (Construction) 8 534 15.0 48XXX Containment--Steel Structures and Supports 8
502 6.8 (Construction)
~
Humber of Number of Percent of Di f ferent Times
!odules Reactor Inspection Modules
!!odules No t-Cl ea r flodular Series Inspection Functional Area Perfonned Performed Inspection 49XXX
' Reactor Coolant Pressure Boundary Piping 8
331 9.7 (Construction) 50XXX Reactor Vessel, Installation, Internals and 15 591 4.2 Caaponents (Construction)
SIXXX Electrical Components & Systems (Construction) 10 415 7.0 52XXX Instrumentation--Components & Systems 10 238 4.2 (Construction) 53XXX Containment--Penetrations (Construction) 3 150 1.3 54XXX Plant Cleanliness and Housekeeping Controls 2
137 8.0 3;
55XXX Welding 18 850 6.6 56XXX Calibrations 2
249 17.6 57XXX Nondestructive Examination 2
70 10.0 59XXX Core Safety Limit & Reserve Shutdown System 2
2 60XXX Nuclear Fuel 5
298 13.1 61XXX Surveillance 14 659 10.2 62XXX liaintenance 2
269 19.3 63XXX Construction Testing 1
11 69XXX Research Reactor Experiments, Long-Term Shutdown 3
68 16.2 and Class H Research Reactor Inspection 70XXX Preoperational Test Procedure Review, Verification 59 1,035 2.1 Test Witnessing, Results Evaluation, etc.
e
o Number of Number of Percent of Different Times Modules Reactor Inspection Modules Modules Not-Clear Modular Series Inspection Functional Area Performed Perfonned Inspection 71XXX Technical Specifications Review, Canpliance, 8
.1,032 19.6 Review of Plant Operations 72XXX Startup Test Procedure Review, Results 48 653 4.7 Evaluation 73XXX Inservice Inspection Activities 7
406 4.2 77XXX Industrial--Academic 1
1 80XXX Environmental Protection 11 452 29.6 81XXX Physical Protection 30 1,037 24.3 82XXX Emergency Planning 8
605 12.6 83XXX Radiation Protection 10 451 39.5 84XXX Radioactive Waste Systens 7
564 19.5 85XXX flaterial Control and Accounting 8
563 7.3 86XXX Spent Fuel Packaging and Shipping 2
25 16.0 90XXX Reportable Matters and Follow up Nonroutine 11 986 11.0 Events 91XXX Title 10 Requirements 2
34 5.9 92XXX Extended Construction Delay, Licensee Event 21 10,170 21.3 Follow up, Follow ups--Unresolved Items, Noncanpliance/ Deviations, Bulletins, Circulars, Immediate Action Letters and Independent Inspection Effort
Number of Number of Nunber of Different Times Modules Reactor Inspection Modules Modules Not-Clear Modular Series Inspection Functional Area Performed Performed Inspection 93XXX Inspector Dispatched to Site and Follow up 2
155
- 21. 3..
on Significant Events 94XXX IE Testimony for Atomic Safety Licensing 5
138 1.4 Board, ACRS, Licensee Meetings, etc.
99XXX "Duniny" Modules used for Reporting Non-19 545 39.1 Modularized Inspections TOTALS 372 28,335 10.k%
l C3 s
~~
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28 TAB'LE 9 ANAL) SIS OF REACTOR' INSPECTION PROGRAM RESULTS t10N-f10DVLARIZED (00 titty) IriSPECTI0ilS OtiLY THREE YEARS ENDED JUNE 1978 Dummy liodules Inspection Functional Total Number Percent Not Series Area Reported Clear,
99001 Abnornal Occurrences 11 55%
~~
99002 Emergency P1anning 8
50%
99003 Environmental Protection 2
50%-
99004 General Health and Safety 31 52%
99005~
ttaterial Control and 36 33%
Accounting 99006
?!uclear Safety 14 14%
99007 Plant Security 62 42%
99008 Radiological Protection 40 28%
99009 Reactor Construction 156 42%
990010 Reactor Safety 54 28%
990011 Transportation 4
25%
990012 Light-Water Reactors 13 23%
Under Construction 990013 Light-Water Reactors 49 39%
Being Decomraissioned 990014 Investigations 47 45%
990015 Three Mile Island Inspection 14 79%
per Sandia Study 990016 Test and Startup (Region II) 1 990018 Vendor Inspection 1 990019 High Temperature 1,
990020 Not Otherwise Identified 1 TOTAL
-545 39%
mo m
7 W Mau ' W,J u
.mt in J
29 OIA note'd that, in a number of instances, the IE inspection program did not provide significant coverage of some functional areas prior to the operations phase. However, in most instances where such coverage did exist, the rates of "not-clear" results were much lower than during the operations phase. OIA believes the three-year inspection results data is indicative of a need for more intensive inspection efforts in certain areas. For example, we believe more intensive, earlier inspection efforts would appear warranted in such areas as radiation protection, environment protection, radioactive waste systems, design, design changes, modifications, etc., procurement activities, operating staff training, procedures, technical specifications, maintenance, and calibrations.
Although we did not perform a trend analysis of the inspection results data during the three-year period, we compared the results for that period with the following nine-month period July 1978 through March 1979 (the incident at Three Mile Island effectiely disrupted the normal NRC inspection program near the end of March).
The data for this later period is also not fully representative or comparable because NRC initiated the revised inspection program (RIP) in July 1978. However, only 20 resident inspectors had been assigned by the end of December 1978. The resident inspector feature of RIP is the principal difference from the earlier reactor inspection program.
There are no nomal levels of noncompliance findings from any inspection modules perfomed a significant number of times. However, we believe from our anelysis that certain functional areas had unacceptably high rates of noncompliance, indicative of poor licensee perfomance in these areas. As noted earlier, OIA is concerned that higher rates of noncompliance are evidenced during the operational inspection phase.
We would expect noncompliance in this phase to be lower than in e.arlier phases. This is because the inspection program is designed and phased to follow the licensees performance from the very beginning of the project through its completion in a manner which should tend to assure that licensees are prepared to comply with NRC requirements in sach stage of development.
If fully effective, we believe the IE program when applied to a licensee during the ten or more years prior to the granting of an operating license, should result in a higher degree of compliance during the operations phase. We recognize that there are many more specific NRC regulatory requirements with which licensees must comply under an operating license than a construction permit, and this could possibly account for the higher statistical rates of "not-clear" inspection modules during the operations inspection phase. Nevertheless it appears to us that as the IE program is designed to test the adequacy of licensees management control systems, it should also assure that these systems are in place and are effective prior to the issuance of operating licenses.
- Thus, while there may be more NRC requirements with which to comply, we would expect licensees to have mature management control systems able to cope with any increased regulatory requirements.
For the functional areas I
showing the highest overall percent of "not-clear" inspections, we compared the rates of "not-clear" results by phase.
Our analysis follows in Table 10.
T wM
TABLE 10 "NOT-CLEAR" INSPECTIONS, HY PilASE TilREE YEARS ENDING JUNE 30, 1978
~Functicnal Pre-Construction Permit Construction Penuit Preoperational Test and Startup Operational Are3-(Modulo Number Percent Number Percent Number Percent Number Percent Number Percent S7rins)
Performed Not Clear Performed Not Clear Performed Not Clear Performed Not Clear Perfornied Not Clear 83 2.4%
22 22.7%
346 49.4%
83 Radiation Prstection 80 Environmental 27 147 126 17.5%
75 1.3%
224 47.8%.
Protection 506 15.0%
E' 22 18.2%
181 Physical Protection 211 22.3%
37 Design, Design Changes, etc.
18 16.7%
6 16.7%
9 11.1%
122 22.9%
93 Inspectors Dispatched to Site and Follow up on Significant Events 117 21.1%
38 Procurement Activities 9 27 22.2%
996 19.7%
71 Technical Speci fica tions 41 Operating Staff 21 -
338
_. 21.0f 84 Radioactive 158 1.3%
24 12.5%
332 27.5%
W2ste Systems
^
's e
4 Functional Pre-Construction Penait Construction Pennit Preoperational Test and Startup Operational Arca
- (flodule Number Percent Number Percent Number Percent Number Percent Number Percent
,Stries)
Performed Not Clear Performed Not Clear Performed Not Clear Performed Not Clear Performed Not Clear 269 19.3%
62 Maintenance 56 Calibrations 249 1 17.7%
68 16.2%
69 Research Reactors -
Experiments Long-Tenn Shutdown, etc.
25 16.0%
'86 Spent fuel Packaging and Shipping
$d 47 Containment--
534 15.0%
Concrete 15 16 209 17.2%
39 R: cords, Doc-ument Control cnd Storage 338 21.0%
~
42 Procedures 26 198 2.5%
60 Nuclear Fuel 29 13.8%
28 7.1%
241
~13.7%
82 Emergency 99 506 15.0%
Planning 90 Reportable 32 6 12 8.3%
936 11.4%
Matters 61 Surveillance 57 Hondestructive Excmination
32 Nonconformance with Provisions of 10 CFR Each inspection finding which is determined to be unacceptable compliance with NRC regulatory requirements is classified as a particular kind of noncompliance. Several hundred items of noncompliance are defined and catalogued in the IE Manual and keyed to specific provisions of 10 CFR or to license conditions, technical specification requirements, licensee commitments, etc. NRC reactor licensees, although principally regulated by 10 CFR Part 50, may also be authorized by their reactor licenses to possess and use byproduct, source and special nuclear material and thus are subject to other 10 CFR requirements.
The IE Manual, in addition to coding items of noncompliance to applicable regulatory requirements.
also indicates a severity level for each such item.
Severity levels are used to assign action points to items.of noncompliance for computing on a cumulative basis a numerical grade score for a period of time (normally twoyears). The accumulation of 100 points has been established as the threshold level at which civil penalty enforcement action must be considered.
The highest level of noncompliance is termed a " violation" and entails 100 action points. Less than one percent of all items of noncompliance cited since the inception of NRC have been " violations." The other levels of noncompliance are called " infractions" which entail 10 action points and " deficiencies" which entail only 1 action point.
IE officials believe the point ratios of 100,10 and 1 represent the relative seriousness of the three levels of noncompliance.
Regional office directors nay, under special circumstances, assign a higher or lower level to an item of noncompliance than that shown in the catalog of noncompliance. Most noncompliances cited have been " infractions" ranging from 61 percent in 1976 to 71 percent in FY 1978 and " deficiencies" accounted for from 38 to 28 percent. Table 11 is 01A's analysis of noncompliances cited against reactor licensees during FY 1976, FY 1977 and FY 1978 (see page 34).
It is apparent from Table 11 that most 10 CFR violations fall in three areas:
Appendix B to 10 CFR Part 50; Facility licensee conditions and Tech. Specs.; and Physical protection of plants and materials, 10 CFR Part 73.
Our analysis disclosed that the percentage of noncompliances classified as violations of Appendix B varied from 28.5 percent in FY 1976 to 30.9 percent in FY 1979. Our detailed analysis showed that several times more noncompliances are violations of Appendix B, Criteria V- " Instructions, Procedures and Drawings " than with any of the other 17 criteria in Appendix B.
Such violations accounted for from about 10 to 14 percent of all noncompliances during the three years.
Although both the number and percentages of noncompliances associated with license conditions and Tech. Specs, declined during the period, this has continued to be the single largest area of noncompliance.
Our detailed analysis showed that within this area violations of administrative controls was most frequently cited and accounted for 26.7, 26.6 and 23.2 percent during the three-year period. While the number and percent of noncompliances citing 10 CFR Part 73 increased most significantly during the period, we believe this may be largely attributed to the adoption by the Commission of Part 73.55 in 1977 and its initial impact on reactor licensees.
33 OIA believes as noted earlier in this report that the apparent continued!
relatively high ' rate of noncompliance with NRC regulatory requirements in certain areas may indicate that additional inspection emphasis is needed to attain higher levels of compliance. We also believe that consideration should be given to nonpunitive measures which might induce higher degrees of compliance, such as educational and informational programs directed toward licensee officials and workers.
OIA INTERVIEWS WITH REACTOR LICENSEES To help evaluate anigain additional insight into the NRC reactor inspection program, 0IA met with representatives from 23 utilities (five utilities each in Regions I, III, IV, and V, and three utilities in Region II) to discuss their views concerning the NRC's reactor inspection program.
The 23 utilities have a combined total of 113 nuclear pcwer plants' (17 planned, 64 under construction, and 32 in operation) which we believe provided an adequate cross section of reactor licensees. The licensee officials, who were in middle and upper management positions, generally were supportive of the NRC reactor inspection program, but, as evidenced by the comments we received, they believe various changes are needed in the inspection program.
Their foremost concern was that increasing numbers of NRC inspections might actually have a detrimental effect on the safe operation and construction of their plants.
Other comments received covered a wide spectrum and encompassed most aspects of the reactor inspection program.
For ease of presentation, we have combined the utilities' comments into the following groups:
Quantity of NRC inspections; Quality of inspectors and inspections; Communication with the NRC; NRC inspection reports; Inspector feedback; and Unresolved items.
Following is our synopsis of the comments we received during our intervicws:
QUANTITY OF NRC INSPECTIONS Ten licensees we contacted had no comments or no problems with the frequency of NRC reactor inspections.
Of these licensees, the general feeling was that if the utility wanted a nuclear plant, they had to be willing to accept NRC inspections.
Nine licensees commented that NRC inspections are too frequent, unnecessarily tie up plant personnel, and have a possible detrimental effect on safety. Two utilities commented that more frequent inspections during certain phases of construction and operation would be beneficial.
Comments concerning too frequent inspections included:
The frequency of inspection is too great. Each of our operating plants gets anywhere between 25-35 inspections per year.
The amo'unt of inspections has been increasing over the last few years.
NRC' inspections are too frequent; why are there so many inspections?
What is the statistical evidence to warrant such frequent inspections?
TABLE 11 SultMARY OF NONC0f1PLIANCES WITH TITLE 10 CODE OF FEDERAL REGULATIONS FY 1976,1977 AND 1978 Part 10 CFR FY 1976 FY 1977 FY 1978 Percent (15 months)
(12 months)
(12 months)
(FY 1978) 19 Notices, Instructions and Reports to 24 13 11
.5%
Workers; Inspections 20 Standards for Protection Against Radiation 126 122 116 5.5%
21 Reportin9 of Defects and Noncompliance 14
.7%
30 Rules of General Applicability to Domestic 2
(a Licensing of Byproduct Materials 50 Licensing of Production and Utilization of Facilities General 56 45 23 1.1%
Appendix B (Quality Assurance) 625 565 654 30.9%
Appendix J (Containment Leakage 4
5 2
.1%
Testing) 1 Facility License Conditions and 953 889 780 36.8%
Technical Specification Requirements Safety Analysis Report Canmitments 1
2 3
^
.1%
Safeguards License Conditions 203 108 51 2.4%
i l
Materials License Conditions 6
2 Vendor Deviations 4
7 5
.2%
' Part 10 CFR FY-1976 FY 1977 FY 1978 Percent (15 months)
(12 months)
(12 months)
(FY 1978) 55-Operators Licenses 12 10 9
.4%
70 bomastic Licensing of Special Nuclear 30 26 21 1.0%
Material 71 Packaging of Radioactive Material for 5
10 23 1.1%
Transport and Transportation of Radioactive Material and Under Certain Conditions 73 Physical Protection of Plants and 146 105 406 19.2%
Na terial's TOTAL 2,195 1,911 2,118 100.0%
if X
9 9
k e
9 T
2
36 The NRC comes in and nakes frequent inspections and then does not give the utility sufficient time to take corrective 6ction before they are inspected in the same area again.
There are too many redundant inspections by NRC and other organizations.
Other organizations should check and use NRC inspections as a basis and framework for their inspections.
NRC~ should take a more active role in trying to coordinate these inspections.
The two comments concerning more frequent inspections were:
We would welcome more inspections during the 30-60 percent stage of completion (electrical and conduit work). We believe frequent NRC inspections would be helpful at this point.
We would definitely like more NRC inspection effort during certain phases of construction and operations.
The utility would definitely benefit from this increased inspection exposure.
OUALITY OF INSPECTORS AND INSPECTIONS Generally, most of the licensees indicated that the quality of the NRC inspectors visiting plant sites was good.
Some utilities were not satisfied with the qualifications of NRC inspectors, especially specialist inspectors, visiting their plants. However, many of the licensees we met with, even those critical of specialist inspectors, believed that most of the NRC inspectors were technically qualified to discuss and help resolve the various problems that arise during the construction and operation of a nuclear power plant. Comments from licensees concerning the technical competence of inspectors included:
Construction inspectors from the regional office are very qualified to inspect reactor construction.
On the whole, the NRC inspectors are professional and technically competent.
The inspectors that currently inspect our plant are qualified to inspect their respective ar?as.
Some of the inspectors in the past
~
were book (or regulation-reder) inspectors who did not have much practical knowledge of the construction activities they inspected.
The current inspectors seem to be more experienced and knowledgeable in construction areas than the previous inspectors.
Our IE principal inspector comes across as a reasonable and fair inspector. He uses good judgment and the utility QA staff has benefited from his knowledge.
Some of.the negative comments concerning NRC inspectors were:
We don't have many problems with the principal inspectors. The specialist inspectors create problems due to the very narrow scope
37 of their inspection area.
The utility seems to have more problems with the specialist inspectors than with the principal inspectors for the site.
. As far as the utility is concerned, some of the ilRC specialist inspectors who inspect specialty areas would not be qualified to work in those areas if they were a utility employee.
While discussing the qualifications of inspectors, numerous comments were made concerning the quality of flRC inspections. tiost of the licensees consider the flRC's inspection program to be an overview or double check of their own QA programs. Some utilities were critical of the present inspection program, while other utilities believed that the inspection program served a beneficial purpose. Some of the comments concerning the overview aspect of the NRC inspection program were:
NRC audits do serve some useful purpose in keeping the utility QA staff on its toes. Gives the QA staff a yardstick to measure their perfonnance by.
NRC inspections serve a somewhat useful purpose, acting as a double check on the utility's QA organization.
NRC inspections are effective in keeping the utility's QA staff on its toes.
The itRC insper. tion progr:m is helpful in the following respects:
(1) Licensee QA program tries to stay ahead of NRC.
This keeps the site QA program on top of most problems that arise at the site; and (2) ilRC program sort of " tops off" the utility's QA program.
It provides a complement to the work of the QA staff.
Negative comments relating to the current reactor inspection program included:
The inspection effort of pre-1970 was probably better than the current inspection effort (since the introduction of Appendix B).
The NRC reactor inspection program over the past four years has become somewhat of a joke.
The inspection program currently contains too much " nit-picking." Over the last few years the inspectors have not looked at the substantive safety issues.
The inspections i
are no longer relevant to public health and safety.
In operations inspections, too much time is spent on record review and not enough time spent on observation of the plant and plant activities. The quality and attitude of the plant personnel to run the plant are the things that NRC should be looking at,
38 Several utilities which indicated that the flRC inspection program was beneficial to them had the following comments:
L The flRC inspection program, as applied by the region, has been meaningful and adequate.
f4RC inspectors have taught the utility QA staff nany useful ideas.
fiRC inspections served a useful purpose in helping get a better trained operating staff than the utility would have hired.
From an operating point of view, there is a definite need for the f4RC inspection program. This is due to the large amount of unused safety equipmant in a nuclear plant versus the amount contained in a fossil plant.
~~
C0fEUf1ICATI0ft WITH THE i;RC One area in which most of the licensees gave the f4RC high marks was in regard to communicating with the inspectors and the regional offices, liost of the utilities said they had no communication problems with the regional offices as indicated by the following comments:
The utility has a free and open communication channel with the regional office. The top management in the region are very competent, and they understand the problems associated with building a nuclear power plant.
Good communication with the region. We feel we can call and talk to all levels of management whenever a problem arises.
fio problem communicating with the regional office. Don't hesitate to call the regional director down to the project inspector, if needed.
Have no problem communicating with the regional office. All the supervisory personnel are responsive to our inquiries, and we don't hesitate to call when we have a problem.
ilot all of the comments we received were positive, as evidenced by the following comments from two licensees:
We have had some ccnmunication problems with the regional office, especially our previcus principal inspector.
Communications with regional inspectors tend to be difficult at times.
Sometimes in the course of an inspection, the inspectors don't explain to the utility personnel what they want to look at.
4 39 A closely related area, for which comments were received, was that of entrance and exit conferences. Most of the licensees stressed that it is imperative to have clear entrance and exit conferences in order to minimize misunderstandings or problems upon the issuance of the inspection report. Comments concerning clear entrance and exit conferences included:
No communication problems with the region.
Good clear entrance and exit conferences.
Entrance / exit conferences are clear and the utility is kept infomed during the inspection of what is being done (and found).
In most instances, exit conferences and inspection reports do match each other. When changes will be made in the report, the regional inspector will call to notify the utility of the changes to be made.
Items that are mentioned in the exit conference usually appear in proper perspective in the final inspection report.
Other utilities believe they have (or had) problems with inspection entrance / exit conferences.
Comments received from these officials were:
Inspections should start out with a good entrance conference. At times, the communication at the entrance conference is so bad, the utility does not know what *1RC wants to accomplish during the inspection.
Poor communication during exit conferences has caused problems when the inspection report is issued. Utility was cited for items they did not believe would be in the report.
Better communications during the exit conference would eliminate many problems. '
During exit interviews, licensee told about certain items that were not considered to be significant, yet they appeared in the inspection report as noncompliances.
NRC INSPECTION REPORTS Several utilities commented that the NRC inspection reports convey a negative attitude of the results of an inspection even if the inspection was clear.
Comments we received included:
A more positive attitude should be expressed in the inspection reports when it is warranted.
NRC inspection reports seem to bring out to the public the negative I
aspects of the licensee's operations. The inspection reports list all of the items that are examined; therefore, by inference, if no negative comments are nade, then the areas are acceptable. This philosophy does not come across to the public.
Tlb=
a AD l
'D D
M 1
40 Instead of-inspection reports which show three levels of noncompliance, MC should issue a periodic report card to the licensee detailing good and bad points in the licensee's operations.
Inspection firdings need to be put into perspective in the inspection report.
Public can't relate what was found versus what was inspected.
Negative wording in inspection reports is tough from a public relations standpoint. Licensee understands the ceaning of the terminology useo, but the public doesn't.
During the course of our audit, IE changed the fomat of their reactor inspection reports. We received the following comments concerning the change:
The new inspection report fomat is auch better than the old report.
The new report is not as redundant and it is very easy to detemine
' what items need to be responded to.
The new inspection report fomat is a large improvement over the previous fomat.
It is now much easier for the utility to detemine what items they need to respond to.
Ii1SPECTOR FEEDBACK We received many comments from the licensees concerning NRC inspector feedback during the conduct of an inspection. According to the utilities, the inspectors apparently act as an informal clearinghouse, passing along infomation concerning similar problems at other plant sites and providing informal advice to the resolution of problems. Most of the utilities consider this to be a very beneficial part of the inspection program and welcome inspector comments on an infomal basis. Comments we received included:
Inspectors do tend to give their unofficial opinions and advice regarding utility operations.
Some of the comments are useful and are instituted.
~
Inspector comments and suggestiv.s are appreciated and considered quite helpful in helping to spot problems before they get out of hand. The utility would like the inspectors to pass along infomation more often.
Feedback that flRC inspectors give the utility concerning problems at other plants is good. Helpful in locating possible problem areas before problems get too large.
Experiences that tiRC inspectors have had at other sites allow the l
utility's QA staff to pick up pertinent infomation concerning the QA area.
41 i
UNRESOLVED ITEMS
..In a recent GA0 report covering,NRC's reactor construction inspection program, GA0 was critical of inspector follow up and close out of unresolved items. Comrents we received from several licensees are counter to the GAO findings. The licensees generally believed that follow up of unresolved items is one of the strong points in NRC's reactor inspection program and that the program would lose most of its integrity if the inspectors were to not follow up on unresolved and open items.
Comments we received included:
As a credit to NRC inspectors, they have never failed to check on an unresolved item or a questionable area found during a previous inspection.
Regional inspectors follow all items found until they are res'olved.
They do not let things slide or " fall through the cracks" once they are discovered.
The inspectors always check open items and noncompliances on subsequent inspections.
At the same time the licensees were praising the follow up of unresolved items, two licensees indicated that'some inspectors tend to abuse the unresolved items list to pressure or " ratchet" the utility. Comments we received concerning this area included:
It appears that the region uses the unresolved items as a tickler file, yet these items are presented in the inspection report and then get into the PDR.
The inspector's unresolved items can be a real problem. As far as the utility views it, the unresolved items are a ratcheting device used by the NRC inspectors.
OIA SURVEY OF REACTOR INSPECTORS' VIEWS AND CONCERNS 3
To better evaluate and obtain another perspective of the reactor inspection program, we solicited the views and comments of IE regional inspection staffs chrough the use of a survey quest.~annaire. Our questionnaire, distributed in Regions I, III, IV, and V, was given to management officials in the regions as well as to the individual reactor inspectors. We received responses from 61 individuals, which are summarized below and included in total as Appendix 1.
UNIFORM Il1PLEMENTAT10N OF REACTOR INSPECTION PROGRAM Seventy-five percent of the inspectors responded that they believe the modular inspection system tends to ensure a unifona implementation of the IE reactor inspection program. Twenty-five percent responded that the modular inspection program does not ensure unifonn implementation of the ~IE reactor inspection program.
Several comments received were:
7 42 The system does tend to standardize inspections.
There is still a question in my mind with r'espect to the implementation of the inspection process at other regions. ' How do they interpret module requirements, how much detail do they go into, etc.
It helps establish unifonnity, but certaiA Ces e ensure it.
I
/
have noticed large discrepancies in the 4/mdulu are done by different inspectors, particularly fror: c e regbn to another. The system is good, but interaction between (fe inspectors perfonning the modules is a must to ensure unifonnity, particularly in highly specialized or technical areas, where all the rigid details couldn't be in a module.
The inspection program is only os effective as the inspector.
Unfortunately differences between inspectors must somehow be minimized.
The modular inspection system merely defines inspection areas'.
Effective branch management ensures uniformity.
Most of the comments received indicated that the modular inspection program could not ensure complete unifonnity due to variables between inspectors, interpretations, and regional management.
liiSPECTI0ti RE0VIREMEilTS OF LITTLE 0'R ii0 VALUE Fifty-nine percent of the inspectors responding believe that there are some inspection requirements that are of little or no value. Thi rty-nine percent of the inspectors responded they believe that all of the inspection requirements have some value. Several of the comcents we received concerning unnecessary inspection requirements included:
Some steps required in the modules could better be handled on a generic basis rather than in an individual module, i.e., receiving inspection, licensees' audits, welder qualifications. The required inspection of in-service inspections could better be perfonned by generalizing Section II of the requirements.
Yes. The requirement to look at storage conditions on all modules.
There should be one module for inspection of storage conditions, and it should remain open throughout the construction phase and be inspected each inspection.
Excessive repetition of some items.
Example--receipt inspection requirements under various x.odules result in multiple inspections of same people and procedures in many cases, with different hardware the object of the different tiRC inspectors.
FLEXIBILITY OF It4SPECTI0fi PROGRAM Seventy-nine percent-of the inspectors responding believe the current inspection program is sufficiently broad and flexible enough and does
-not confine and limit the scope of inspections. Most of the inspec, tors i
43 commented that the modules tend to insure that certain specific areas are inspected and that, if used as a minimum requirement, the modules are not too confining.. Inspectors also commented that the independent inspection effort that is allowed provides enough flexibility for them to dig into certain areas. Twenty-one percent of the inspectors responded t' ?t' they believe the current inspection program is too' confining and ions not allow enough flexibility.
Inspectors tended to believe that, wcile the scope of the inspection program was broad enough, the inspection module line items were too confining:
It is broad enough in scope but too confining in the line item requi rements.
The number and types of samples required are not realistic to what is encountered in the field.
If you are looking at the pipe installation program, what does it matter what systems you look at as long as it is safety related?
Inspectors also commented that pressure to complete the modules scheduled for inspection had a limiting influence on how far they would follow a
. problem area.
.IttDEPENDENT INSPECTION EFFORT Seventy-seven percent of the inspectors who responded believe that sufficient time is allowed for independent inspection effort (IIE).
Currently, the inspection program allows 20 percent of the inspector's time to be allocated for increasing the breadth and depth of an inspection beyond the module requirements. This allows the inspectors time to follow up on items of interest found during an inspection. The inspectors believe that if this time is used judiciously, then it is adequate enough to meet inspection needs. Comments included:
1 Yes. Again, this must be properly utilized and the purpose well understood by the inspectors.
If there is a need for additional
" independent inspection effort," it should be approved by supervision to preclude an inspector spending all his time in " pet" areas.
Yes. A mandated amount (say 20 percent) will undoubtedly result in a figure close to the amount in manpower figgres.
(It is very easy to justify 20 percent in your mind.)
I think that some preapproval of IIE should be required in office, prethought at any rate. An inspector onsite could perfonn other IIE if he thought it more valid. The present problem appears to be that finn goals established for the inspector (complete modules scheduled for inspection) presently outweigh the vague 20 percent time goal, which can easily be justified in the inspector's mind by tours and general discussions with licensee personnel.
Twenty-two percent of the inspectors responding believe that there is not sufficient time to perfonn independent inspection effort or that too much time is allotted for independent inspection effort.
E q
sa Ui!AfiN0UTICED INSPECTIONS In response to our question concerning unannounced inspections, thirty-six percent of the inspectors responded that unannounced inspections hinder their inspection effort.
Sixty-cne percent res;onded that ur.anncunced inspections do not significantly hinder inspection perfemance. Of the inspectors who complained about inspecticns being hincered, most of the-comments concerned the inability to observe work or tests. Typical coaments concerning the hindrance of inspections included:
Yes. Particularly in in-service inspection (ISI) effort. Nearly every ISI must be announced. since the work to be perfomed varies 50 much and changes during a downtime cutage.
For an ISI or.preservice, the percentage of unannounced is exactly reversed (i.e., 85 percent should be announced).
Construction inspections should have a different definition of'
" unannounced." Say, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />' notice is still " unannounced."
I find the concept of unannounced inspections sccewhat ludicrous.
A regional requirement of 18-days-per-quarter-site time almost guarantees that the inspector travels to the site every other week.
By the process of elimination and previcus history, the licensee can guess inspection areas or ~at least know what areas will not be
~
inspected. This brings to point the computation of the 18 days per quarter, which is absolutely ludicrous.
The only site time that is entered or counted is that reported as regular hours on the manpower system. Why spend extra hours at the site if it counts for absolutely nothing.
Those inspectors favoring unannounced inspections had the following comments:
In general, unannounced inspections have not presented a significant problem.
In some instances it reveals the depth of the licensee's staff when the " expert" in a particular area is out for the inspection.
No. We are present so often that the licensees take it for granted.
Also we have sufficient flexibility such that if key Ieople are not present, we switch over to another area where the key people are present.
In responding to our question concerning announced inspections, 90 percent of the inspectors responding believe that some inspections are facilitated by being announced. Most of the comments indicated that inspections involving observation of work or tests, or inspections where certain licensee personnel needed to be contacted, were facilitated by prior announcement. Typical comments we received included:
Inspection of certain items such as large concrete placements, heat treating containment vessel, installing reactor pressure, etc.,
need to be coordinated with licensee and they are, in effect, announced because we ask to be infomed when they will be accomplished.
D
45 All pre-op [ pre-operational] and special tests. inspections that require witnessing something; when key people who work odd hours are involved; these must be scheduled. Key people who have major plant responsibilities must be scheduled so that they have time to devote to you and are at the site and not on vacation or sick
-leave.
Yes. When a licensee knows you are coming, they work hard to correct their weaknesses.
Corrective action is what it is all about.
This way the licensee and contractors help you do your job.
If there are ten construction activities, he has no way of knowing which you will look at.
RESULTS OF~ R'N0UNCED INSPECTIONS Eighty-seven percent of the inspectors responding believe that results of announced inspections are not (or would not be) different from those of unannounced inspections. These inspectors believe that the licensee could not (or would not) change any methods of operation just because an NRC inspector is coming:
No. Generally licensees don't have the nanpower nor the will to
" bone up" for an inspection. They are much too busy making megattatts to worry about NRC inspections.
No.
If there are serious deficiencies in the QA/QC [ quality control]
activities, don't believe that a few hours' notice or a day would allow them to be corrected.
No. Unless you believe that the licensee lies, there is no basis.
If his records are not up to date, he couldn't possibly fix them in the short time before the inspection is begun.
Every inspector should call the site before he leaves the office if there is any question in his mind that the thing or individual he needs to see will not be available.
Most inspectors believe that, in order to better utilize their time and the time of licensee personnel, more announced inspections should be perfomed.
APPROPRIATENESS OF UNANN0UNCED INSPECTION POLICY The inspectors responding to our questionnaire were almost evenly divided concerning the appropriateness of the unannounced inspection policy (TI 1200/1).
Forty-six percent of the inspectors believe the policy to be appropriate, while fifty-one percent believe the policy needs to be changed.
Arguments for announced inspections included:
Generally, yes.
However, that portion dealing with varying motels, car rentals, etc., borders on being ridiculous and could present a hardship on inspectors.
Few, if any, licensees have the expected
~46 arrangements with motels, etc., and those that do, 3re known to the inspectors. A few false alarms would indicate to the licensee that they've been found out.
Yes. _ However, I feel the NRC has " shot itself with its own gun" by emphasizing arriving on site " undetected" by the licensee and then involving new security requirements that do not exempt the inspector and, therefore, prevent the inspector from getting into the facility without a long time delay.
For example, when arriving at a site, the inspector may spend anywhere from 15 to 45 minutes getting into the facility thus assuring the licenses a chance to prepare for the inspector.
Yes. Because it gives the public confidence in that the aspect of an announced inspection gives the appearance of collusion between the inspectors and the licensee.
Typical comments received from those inspectors who favor a change in the policy included:
Disagree. Only a small portion of the inspection program warrants unannounced effort.
In the present program, we are auditors more than reviewers / observers. The licensee nomally either has the appropriate records or doesn't~
He would not nonnally have time to alter records because we 6udit electively.
No.
It was made this way to satisfy outside pressure and to present our image.
It was not made to enhance the inspection program..The NRC is responding to pressures which in turn directs our policy, not because it will be good for the inspection program.
We don't have unannounced inspections. The licensee can prevent our entry into the site or specific locations through administrative requirements our management requires we observe. These delays can be as long as one day and many are specific to NRC inspectors.
ADE0VACY OF ENFORCEMENT MECHANISMS Fifty-nine percent of the inspectors responded that current IE enforcement mechanisms are adequate to ensure licensee compliance with NRC safety requirements, while thirty-eight percent of the inspectors do not consider the current enforcement mechanisms to be adequate. The general opinion was that enforcement problems usually arose with.the irresponsible licensee, and this is where the system might be inadequate.
Other inspectors questioned the monetary impact of a civil penalty on a reactor licensee.
Typical responses on both sides of the issue were:
They are adequate. However, enforcement mechanisms do not ensure licensee compliance nor should they.
Compliance is ensured by licensing responsible and competent organizations.
l I
47 Yes. However, if I were a licensee and had to choose between shutting a plant down for several days or taking a $25,000 fine, it would be hard to explain why I chose the first.
Nothing is totally adequate to ensure compliance. The-most meaningful vehicle is licensee management enforcing safe operation.
I feel the NRC monitors performance at licensees when inadequacies are perceived.
Enforcement mechanisms can only be effective when they can be backed with teeth. At best, the worst we can do to a licensee is embarrass him. Our civil penalties are equivalent to parking meter charges.
Monetary values of civil penalties do not hurt large utility pocketbooks.
f' ore attention is needed with respect to licensees who receive large numbers of citations--known bad actors should receive more
'hard-nose attention.
00ALITY ASSURANCE pR0 graft When asked whether NRC devotes ne proper proportionate amount of time to the inspection of a licensee's QA program, 63 percent of the inspectors responded yes, and 33 percent responded in the negative. Most of the inspectors felt that inspecting the licensee's QA program for proper implementation was the nost important aspect.
Some of the comments included:
No. The Ccamission approach is geared too much to finding a technical defect rather than finding if the licensee system is working properly.
Fifty to one-hundred people are working to keep construction activities straight versus a one-on-one situation, an NRC inspector looking at an activity. A systems approach is the only way.
I believe that less time should be spent reviewing the paper of the licensee's QA program. Greater emphasis should be spent in assessing the implementation and effectiveness of the program.
ACTI0a ITEM TRACKING SYSTEM (AITS)
The AITS is used by IE to control communications within IE and between IE and other NRC offices. The inspectors responding to our questionnaire were almost evenly split on the adequacy of the AITS.
Forty-one percent of the inspectors consider the AITS to be an adequate system for communicating within IE and between IE and other offices. Thirty-six percent consider the AITS to be an inadequate system.
Several inspectors indicated that the biggest drawback to the system was the quality or responsiveness of the answer received from the answering office. Other comments indicated that once an AITS item left IE for another NRC office, IE had no control over when an answer would be received.
i 48 RESP 0NSIVENESS OF TRAINING PROGRAMS Forty-three percent of the inspectors responding believe that IE Headquarters and regional office training programs are responsive to the needs of the inspectors.
Fifty-five percent of the inspectors do not believe the training programs meet the needs of the inspectors.
Several inspectors indicated that~IE needs a course on inspection techniques (which has since been implemented) to help improve inspector perfomance.
It should be noted that inspectors must satisfactorily complete certain training courses in order to continue to inspect at reactor sites. Some of the comments we received were:
Only partially. We learn a lot about plant systems, which you forget soon af ter the course, but we learn hardly anything about being a good inspector.
Significant improvement is desired to differentiate between " nice to know" and "need to know." NRC is spending too much money on training programs which do not cater to inspection-required acts.
No. Because there is no practical experience input from experienced inspectors.
Refresher training should be done in the region and the field inspectors should not only attend but should also participate in the instruction effort.
No. Need an inspection techniques training course for inspectors.
Too much emphasis placed on technical aspects of job and much of this technical matter is never used.
INSPECTOR EVALUATION OF LICENSING DOCUMENTS We asked the inspectors whether they should have more involvement in review and evaluation of the licensee's Safety Evaluation Report, Safety Analysis Report, and Technical Specifications.
Sixty-three percent of the inspectors responded yes, that more involvement is needed, and thirty-seven percent that more involvement is not needed.
Some of the inspector comments included:
Involvement as required by the inspection program is adequate--if the question means should IE inspectors have an " approval" function, no, that is solely the responsibility of NRR.
Yes.
"The wearer knows where the shoe pinches."
Because of the importance of wording and word usage during the course of inspection and enforcement activities, it is imperative that IE inspectors get involved in the above-mentioned activities to insure that enforceability of requirements is enhanced and uniformity is established.
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i UTILITY POLICIES A'lD PRACTICES DURIf1G IflSPECTI0f15 The inspectors were almost evenly split when asked whether there were any utility practices or policies which restricted inspection perfomance.
Fifty percent of the 1:.apectors believe there are some restrictive utility practices or policies which inhibit inspection perfomance.
Forty-eight percent of the inspectors believe that inspection perfomance is not inhibited by utility practices or policies. Of the comments concerning restrictive utility practices, security policies seemed to cause the inspectors the most problems:
Failure to allow inspectors free access of the facility (except controlled areas).
Note this problem is worsened by the t1RC requirements.
The flRC security requirements as practiced by the licensee will sometimes delay an inspector at the gate.
The new 73.55 " buddy" concept will severely restrict free access.
Freer access to the plant would help.
The inspector should not have to wait at the gate while a guard contacts the licensee to obtain pemission for entry.
The tendency on the part of some utilities to rely upon our findings as a perfomance measurement for their people.
Too of ten we find utilities transferring or releasing people as a result of f1RC findings.
A closely related question we asked dealt with the licensee's use of escorts during an inspection.
Fifty percent of the inspectors responding indicated that they are usually required to have a licensee escort while conducting an inspection.
Forty-eight percent of the inspectors indicated that' no escort is usually required during their inspections.
On the inspections we observed, we noted that the inspectors usually had a licensee escort but that this did not tend to inhibit the inspection effort.
The inspectors indicated that although they might have to be escorted, this did not significantly hamper their inspection perfomance.
Some of the comments received were:
Yes.
They usually accompany and for my safety and ease of finding required areas; I am satisfied the accompaniment is desirable.
They do not hinder me and I leave them behind when I climb too high for them.
flo. When representatives accompany me they have always been a big help.
The people at a facility are always anxious for you to find areas that they think might be a problem.
They'll lead you to them but, of course, they don't always tell you what their concerns are until you start asking questions.
Yes (85 percent).
(1) This hinders when no one person is identified as your escort, you spend time waiting on escorts.
(2) After hours, inspectors are oftentimes limited to the control room due to lack of
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(3) Having a knowledgeable guide is a plus when trying to find a specific paper, pump, area, etc.; however, this cuts down the free roaming of inspectors where items are often found.
SUPERVISORY CHANGES f1ADE TO INSPECTION FINDINGS Seventy percent of the inspectors believe that supervisory changes made to their inspection reports are usually warranted, while twenty percent of the inspectors felt that changes were unwarranted.
Comments made by inspectors included:
Sometimes.
But I must say frankly, that I have been indirectly reprimanded for failing to follow supervision's interpretation of inspection findings.
They make it perfectly clear what they want you to. find.
If you want to continue progressing in your career, you be',ter not oppose them too often.
Supervisory (or peer review) of a report is helpful, when it's meant to be helpful. Where it is done to " bureaucratize" a finding--you know how " helpful" that is.
Seldom are any changes made.
However, they are never made without discussion and concurrence that the facts remain as understood by the inspector that examined the activity.
- IE SUGGESTION PROGRAff We asked the inspectors whether the IE suggestion program appeared to encourage field inspectors to make suggestions for-improvements in IE programs and if the feedback received was responsive.
Sixty-four percent of the inspectors believe the suggestion system is inadequate or unresponsive to inspector comments. Twenty-four percent of the inspectors consider the current suggestion system to be adequate and twelve percent of the inspectors did not comment.
Comments included:
flost suggestions to improve the inspection program are written up in a memo and transmitted through the regional supervision to HQ [ Headquarters].
Action or feedback is dependent on the suggestion.
What is the IE suggestion program???
Have not heard of an IE suggestion program--IE HQ appears totally l
unresponsive or incapable of making any decision--example being the identified need to revise MC 1000, i
I MOBILITY POLICY IE has a mobility policy which basically states that to be promoted to a regional section chief or branch chief, an inspector must be willing to
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move for the' good of the, organization. This issue has been a controversial one, and the inspectors' comments reflected this.
Sixty-nine percent of the inspectors do not agree with the nobility policy. Twenty-seven percent of_ the inspectors agreed with the policy, and four percent of the inscectors had no comment.
Comrents on both sides of the issue included:
I basically agree that an inspector should not be procoted in his own branch but transfer to another branch should be adequate " mobility" since it would provide a different technical background.
The policy was and is poorly handled by 11RC management.
It's a sham and a fraud.
It's 'ill-conceived, ill-executed, and (with very little effort) has produced amazingly negative results.
I disagree with the policy.
There are many very capable people within a region that would do an excellent job but that cannot be promoted
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due to this policy. These are people who would make excellent supervisors who will not apply for a position because they must become " gypsies" to make the advance.
Don't forget that these are people that are usually in their late middle years with families.
I do not see where the mobility requirement improves the inspection effort.
A good inspector in one region will be a good superv'isor in the region--
a bad inspector in one region will be a bad supervisor in another region.
As a general policy, it can only help the organization.
The policy has not been equitably applied.
(During the past two years, about 50 percent of the 15 promotions have been "in-region.") As a result the policy is discredited and the inspectors do not accept. In only one case, obviously prearranged, has a mobility participant returned to the regions as a branch chief; the others either ended in HQ or got section chief jobs.
The general feeling is that mobility is only a requirement in the " western regions."
It is an excellent progran, but useless unless enforced unifonnly.
CAREER LADDER Seventy-five percent of the inspectors responding have an unfavorable view of the flRC career ladder.
Eighteen percent of the inspectors commented i,
that the career ladder is favorable. As with the IE suggestion program, the inspectors complaia that they are unaware of any ca -eer ladder or exactly what their career employment potential really is.
Comments that were made included:
Excellent. ftake background, experience and perfonnance the controlling criteria for promotions, not time with flRC.
This would foster a healthy, competitive atmosphere with inspectors, causing them to i
perform at increased levels if they intend to get ahead.
1 It looks like a nine-foot chinning bar.
There is little opportunity for advancement, bu'. that is not unlike most organizations.
I think 1
52 that promotion carrots and ginmics like mobility will continue to keep the very best people out of top management.
And that is sad for the NRC.
Basically NRC field inspectors should not be brought up from the college level. People should be selected from industry or utilities for the job.'
ADE0VACY OF OVERALL REACTOR INSPECTION PROGRAM Seventy-eight percent of the inspectors responding believe the current NRC reactor inspection program to be adequate to ensure public health an.d safety. Nineteen percent of the inspectors said that they do not believe the program to adequately ensure public health and safety.
The inspection program appears to me to be adequate to provide the necessary verification of licensee actions which in turn provide the necessary assurance that the licensee is conducting his activity in such a manner as not to constitute an unreasonable risk of harm to the public.
Yes.
If the program is used as guidance and not as something rigid (a checklist), then it is certainly more than adequate.
Public health and safety is why I'm in this job.
I believe in the program, I believe it's basically a good one.
NRC's reactor inspection program works, in spite of the inefficiencies of the formal program, because of the competence and drive of the inspectors.
This is difficult to answer. Our primary function is to motivate the licensee to do a good job and thus ensure the public health and safety.
The amount of NRC man-hours spent onsite certainly by itself provides little direct assurance of safety. The program does provide enough inspection to give a good picture of the licensee's effectiveness.
OTHER COMi1ENTS In concluding our questionnaire, we requested any other comments the inspectors might have. One comment, which concerned the use of clerical personnel, was:
Clerical personnel is sadly lacking. A large amount of the inspector's work could be done by male or female clerks (or subprofessional).
These could do the work better, at one-half the cost.
GAO, in their report on NRC's reactor construction inspection program, raised a similar issue. GA0 recommended that some of the clerical work now done by inspectors be done by paraprofessionals or clerks.
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l Another comment concerned the development of the inspection program by IE officials:
Inspection procedures should be developed by personnel who have had recent experience in the field. The regions should have input or at least a chance to review and comment before procedures are implemented.
Too many of our inspection modules have been written by individuals with little or no field experience or by individuals who are no longer in touch with needs of the inspector in the field.
Some of the other comments received were:
Having been both a project inspector and a specialist, I feel the best
,o inspectors would be developed by periodically rotating inspectors through the various specialist and project positions within a branch.
Reduce some of.the paperwork of the inspectors. At present it takes as long to write and review a report as it does to perform the inspection.
Spend more time on a construction site, to get a better feel of what is being done in all safety-related areas.
An anonymous questionnaire like' this is super.
I think it's a great way to get candid views from the people who are doing the work--the people in the field. Please make good use of this.
I see a lot of destructive forces in the NRC management--a form like this has the potential for offering minagement a little honest guidance.
AGENCY CCMMENTS In commenting on our draft report, IE with the concurrence of the ED0 agreed with our report without substantive comment.
IE advised that they will utilize the report and the survey responses in on-going reviews of the inspection programs. A copy of the ED0's response is contained in Attachment 1.
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