ML19341A536
| ML19341A536 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1979 |
| From: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Ahearne J, Gilinsky V, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19341A503 | List:
|
| References | |
| FOIA-80-516 NUDOCS 8101260308 | |
| Download: ML19341A536 (34) | |
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Cecenter 21, 1979
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liEl:0RANDUM FOR:
Chain an Ahearne Commissioner Gilinsky
. 3 Commissioner Kennedy Commissioner Hendrie
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- FROM:
s J. pdhmings frector ffice of Inspec,- and Auditor
SUBJECT:
yREVIEW0FTHECONTINUINGII;PLEtENTATION OF NRC'S RESIDENT INSPECTION PROGRAM This is the Office of Inspector and Auditor's (01A) second report on the Nuclear Regulatory Commission's (NRC) resident inspection program for reactor sites.
Our first report, issued in June 1979, dealt with the undesirable effects of accelerating the implementation of the resident inspection program.
This report is an evaluation of the overall implementation of the resident inspection program, from inception up to the present time. We have attempted to identify where program goals are being met or revised to accommodate both agency and inspector needs and where further management attention is needed to improve future implementation.
Our aim with this report is to inform the Commission of the results of initial program icplementation of the resident inspection program and help ensure its success.
Our review );ar conducted during the period June through September 1979 at NRC Headquarters and Regions II, IIL and V.
Discussions were held with regional directors, branch and section chiefs, regional inspectors, resident inspectors.and other Office of Inspection and Enforcement (IE) officials concerning the resident inspection program.
As part of our review, ice also visited nine utilities to discuss with upper nanagement officials their views and concerns regarding the implementation and results of NRC's resident inspection program to date.
Contact:
H. Eculden, OIA M. Aterbach, OIA 49-27051
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2 SUMARY OF FINDINGS In the ccurse of our review, 0IA noted several problems and unresolved issues ia the resident inspection program.
Individually, these problems do not appaar to be of. major significance; however, taken collectively, we found they have hampered the implementation and performance of the resident inspection program.
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On the positive side, 0IA found that the resident inspection program has resulted in improved communication between NRC and licensees, provides a permanent NRC contact person at the site, and has resulted in. increased On the inspector's familiarity of the plant where residents are assigned.
negative side, we found that the resident inspection program has not had the benefit of high level, centralized management and control; IE did not meet its goal for stationing resident inspectors at reactor sites by the end of Fiscal Year (FY) 1979 but apparently the goal will be attained only a few months late; resident inspectors are not yet meeting established.
program goals for the amount of direct inspection effort; the number of noncompliances found by resident inspectors is considerably lower than those found by region-based inspectors; there is a lack of accurate cata in the management information system for evaluating the resident inspection program; the role (responsibilities and authority) of the resident inspector on a daily basis and during an emergency needs to be more clearly defined; a career ladder for IE inspectors needs to be developed; finalized criteria need to be established for the selection of resident inspectors; and three administrative problems (i.e., Government vehicles, moving expenses, onsite clerical assistants) still remain unresolved.
CONCLUSIONS The report's overall conclusion is that the lack of high le' :1, centralized management for the resident inspection program has hampered program imple-We believe that this lack of centralized management has resulted mentation.
many of tne problems noted in this report.
The report also concludes a
>.at the issues of (1) qualifications for resident inspectors, (2) defining t.5e role of the resident inspector, (3) development of a career ladder, (4) reevaluation of the "C" level inspection program, and (5) problems in
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administrative areas are indicative of a general lack of management attention by IE Headquarters officials to the implementation of the resident inspection We believe that proper planning prior to, and in the early stages program.
of, implementing the resident inspection program would have alleviated many We also believe that failure to address these problems of these problems.
in a timely manner will tend to exacerbate them, as the resident program is to be greatly expanded in the next two years.
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While we are aware that IE has appointed an individual to act as a resident
" coordinator," we believe this action is not only long overdue, but also insufficient to resolve the problems we have identified.
For example, the resident " coordinator" does not have the authority to implement any of the tasks under study but, rather, has to deal with the appropriate Division Directors to get the work performed.
Although the appointment of a resident
" coordinator" has tended to centralize some responsibility in one person, DIA contends that this action in itself will not resolve the problems that are impeding successful implementation of the resident inspection program.
The expanded resident inspection program is becoming, for all intents and purposes, the major NRC reactor inspection program, and we do not believe a single individual can be responsible for implementing and resolving the problems associated with the program.
RECOMMENDATIONS The overall report recommendation is that IE establish a separate program office to take lead responsibility for the implementation of the resident inspection program. We recommend that the suggested office be a staff office to the Director, IE, headed by -a GS-16/17 (or equivalent), who would be accorded equal rank with the other Division Directors.
Staffing would be by individuals drawn from the other IE program Divisions. Also, individuals with recent field inspection experience should be assigned to assist in the-The development of policies and procedures to provide "real world" input.
office should have full authority for the technical inspection program prescribed to be carried out by the resident inspectors, as well as the responsibility to monitor and evaluate the resident inspection program.
-The report also recommends that IE:
develop an action plan to ensure that the IE management information system is both producing accurate, reliable information and is being used to evaluate program accomplishments; establish a unifonn policy detailing the duties, responsibilities and authority of the resident inspector; reevaluate the "C" level inspection program, to develop a fully integrated inspection program acceptable to inspectors and IE e
management; develop uniform, finalized criteria and qualifications for the selection and assignment of resident inspectors; and take more aggressive steps to resolve the three administrative problems noted above by (1) developing and publishing NRC regulations governing the assignment and use of government vehicles by IE resident and region-based inspectors; (2) cither developing a
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legislative proposal.for the subnission to the Concress to provide authority for the payment of reasonable relocation expenses or finding alternative rethods to reimburse resident inspectors for all reasonable relocation expenses; and (3) developing a uniform policy for providing clerical assistants to-resident inspection sites.
Ar,El.'CY C0"l'EtlTS
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'In responding to our report, the Executive Director for Operations (EPO)
- generally agreed with our findings and reconrendations.
However, the EDO did not concur with our reca,nendation to establish a separate IE staff office to oversee the resident inspection program at the present tine. The EDO stated:
"The lack of centralized planning and information gathering on the Resident Inspector Program had been evident for sone time.
IE recognized this problem and, in early August 1979, appointed a resident program coordinator....I do not agree with OIA's recommendation that a separate IE division be established to direct the Resident Inspector Progran....I feel that the current arrangenent where each IE division continues to exercise its unique functional responsibilities and a coordinator tracks their efforts to the needs of the Resident Inspector Program, is working well."
The ED0 fur ther stated that: "tievertheless, we will be considering the option of establishing a separate division as the program evolves."
Concerning the development of a career ladder, the EDO connented that action is complete:
"A contractor, General Research Corporation, developed a career ladder structure for IE in !! arch 1979. The " unit" inspectors are fully integrated into this structure and can expect to advance to senior resident inspectors, Regional or performance appraisal inspectors, and junior Headquarters assignnents.
Senior resident inspectors can advance to positions as Regional section and branch chiefs or to senior Headquarters assignments."
C OI A C0lTEf!T De have reviewed the career ladder structure developed by the General Research Corporation; however, it is not evident that IE has developed the type of conprehensive career ladder structure we intended. The contractor'made nurerous proposals and reconmendations, and 0IA was D**]D *]Df ooM o mud 2
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unable to defemine t;hich of these 5:ere adopted.
fs'noted in the ED0 response, IE has not yet developed a policy on reassignment of scnior "
resident inspectors after their tour of duty at a site is completed.
OIA does not consider action on this reconce.,dation to have been completed.
The complete response, which explains the actions being taken on seven other 01A reco,cendations in which the EDO concurred, is contained in Attachment I to the report.
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Attachment:
, Subject Peport cc:
L. Gossick, EDO Peads of Offices Regional Directors S
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4 TABLE OF CONTENTS Page 1
INTRODUCTION e
1 SCOPE 1
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' BACKGROUND 2
FINDINGS 3
- LACK OF CENTRALIZED MANAGEMENT 4
Recommendation 1 A-FY 1979 IMPLEMENTATION 6
RE.SIDENT INSPECTION PROGRAM ACCOMPLISHMENTS 7
Intangible Program Results -
9 Quantitative Accomplishments 13 Recommendation 2 14 ROLE OF THE RESIDENT INSPECTOR 15 Recommendation 3 15 f
"C" LEVEL INSPECTION PROGRAM i
Recommendation ' 4 17 i
17 DEVELOPMENT OF A CAREER LADDER l
18 Recommendation 5 19 SELECTION CRITERIA FOR RESIDENT INSPECTORS a
20 Recommenaation 6 F
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Pace 20 ADMINISTRATIVE PROBLEMS 20 Government-Vehicles 21 Reimbursement of floving Expenses 23 Clerical Assistants i '
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Recommendation 7 24 OVERALL-C0flCLUSION 25 AGENCY COMf'ENTS 26 OIA C0fEElli ATTACHMENT I--Memorandum fr. L. Gossick, EDO to J.Cummings dtd. 12/18/79 I
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9 INTPODUCTION This is the Office of Inspector and Auditor's (01A) second report on the Nuclear Reg.atory Commission's (NRC) resident inspection program for reactor sites. Our first report, issued in June 1979, dealt with the undesirable effects of accelerating the implementation of the resident inspection program. This report is an evaluation of the overall implementation of the resident inspection program, from inception up to the present time.
t'e have attempted to identify where program goal are being met or revised to accommodate both agency and inspector needs and where further management attention is needed to improve future implementation. Our aim with this report is to inform the Commission of the results of initial program implementation and to recommend actions we believe will facilitate further implementation of the resident inspection program and help ensure its success.
SCOPE Our review was conducted during the period June through September 1979 at t
NRC Headquarters and Regions II, III, and V.
Discussions were held with regional directors, branch and section chiefs, regional inspectors, resident inspectors, and other Office of Insp.ection and Enforcement (IE) officials concerning the resident inspection program.
As part of our review, we also visited nine utilities to discuss with upper management officials their views and concerns regarding the implementation and results of NRC's resident inspection program to date.
BACKGROUND As explained in our first report, the resident inspection program is one phase of the NRC's Revised Inspection Program, which was approved by the Commission in June 1977.
The original concept was to have one resident inspector assigned to each operating reactor site and also at selected construction sites.
It was anticipated that tha resident inspectors would help to increase the NRC presence at licensed facilities, provide an increase in direct inspection effort, and help improve licensee awareness of NRC regulatory requirements.
Implementation of the resident inspection program started in July 1978, with the stationing of resident inspectors at selected reactor and fuel facility sites.
IE developed a phased implementation schedule, with plans to achieve full program implementation by Fiscal Year (FY) 1981.
The resident in'spection program was designed to complement and supplement the routine reactor inspection program (region based).
To accomplish this, IE developed an inspection program stressing direct observation of site activities to be conducted by the first group of resident inspectors, which consisted of senior level (experienced) individuals selected from the regional offices.
Resident inspection activity is. 'a addition to the specialist support inspections, perfomed by the region-based inspectors, who tend to concentrate on the review of records and procedures.
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2 In July 1979 the Commission approved the " unit" inspector concept, which is designed to supplement the resident inspection program (now referred to as the Expanded Resident Program) and increase NRC presence at reactor facilities.
At this time, the intent is to have at least as many NRC inspectors as units at each operating reactor site, but with no less than two NRC inspectors at single unit sites. Thus, single and dual unit reactor facilities would have two resident inspectors, three unit sites would have three inspectors i
and so forth. One of the resident inspectors at the site will be a senior le"el inspector, with supervisory responsibility over the other inspectors at tNe site. Although planning is still underway, NRC is committed to the Congress to have approximately 170 inspectors in place at reactor sites by September 30, 1981. With this expansion, the resident inspection programt for all intents and purposes, can now be considered the major NRC inspectso.'.
program.
In August 1979 a mid-level IE employee was appointed as " coordinator" for the resident inspection program, with the responsibt?ity for defining, prioritizing and assigning various tasks involved with the development of the resident inspection program.
The " coordinator" interfaces with the program Divisions within IE in pulling together the various tasks associated with implementation of the resident inspection program.
An implementation plan, consisting of eleven priority tasks and six secondary tasks, and which addresses some of the issues raised in this report, was developed by the resident " coordinator" and presented to the Director, IE, for approval, in September 1979.
The plan was approved by the Director, IE, on October 18,
- 1979, FINDINGS In evaluating the implementation of the resident inspection program, 01A has found that:
overall, the resident inspection program has lacked the centralized management and control necessary to resolve policy issues and several complex and unique implementation problems inherent in a developing and expanding program of this type;
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the NRC goal for stationing resident inspectors at reactor sites by the end of FY 1979 was not met, but apparently will be attained only a few months late; the goci of increased inspector familiarity of the plant where residents are assigned is being realized; and better communications between the licensee and NRC has been recognized and is attributed to the availability of resident inspectors as an NRC l
contact point at the site.
3 In addition, 0IA noted several problem areas which we believe are indicative of a general lack of management attention by IE Headquarters to the implementation of the resident program. Many of these problems have been identified for two years and have yet to be resolved by NRC management.
Specifically, we found that:
resident inspectors are not yet meeting established program goals for the : mount of direct inspection effort; resident inspectors are finding significantly fewer concompliances than the region-based inspectors; the lack of accurate data in the IE management information system made it impossible for us to determine if the resident inspection program is resulting in increased inspection effort; the role (responsibilities and authority) of the resident inspector, on a daily basis and during an energency, is not clearly defined; the "C" level inspection program developed for resident inspectors to perform is too detailed and does not direct the inspector's attention to the major safety issues; no formal career ladder has been developed, as called for in the implementation of the revised inspection program; no finalized criteria have been established for the selection of resident inspectors; and administrative areas covered by the resident program (i.e., Government automobiles, moving expenses and secretarial support) were not adequately planned for prior to program implementation.
LACK OF CENTRALIZED MANAGEMENT Although the concept of, and planning)for, the resident inspection program goes back to 1974 (pilot test prograrn, responsibility for the development and implementation of the program has been fragmented within the IE organization.
In apparent recognition of the need for some type of a focal point to bring together information, a mid-level staff member of the IE Executive Officer for Management and Analysis has been designated as the " coordinator" for the resident inspection program.
Based on our current and previous audit reviews of the resident inspection i
program and the issues and problems noted in this report, we believe that a single, resident inspection program " coordinator" is inadequate to insure complete program implementation. We believe that the resident program needs a " Czar" and a separate staff office to deal with the many facets of implementing a program of this magnitude.
4 Recommendation 1 We recommend that IE develop a separate program office to take lead respon-sibility for implementing a rapidly expanding resident inspection program.
Our suggested organizatior, for this office is shown in Figure 1:
'O FIGURE 1 PROPOSED IE ORGANIZATION Executive Officer Resident Inspection Activities IE Director Executive Officer Executive Officer Management Analysis Operations Supp, ort
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Division of Reactor Division of Reactor Division of Fuel Division of Construction Operations Facilities &
Safeguards Inspection Inspection Materials Safety Inspection Inspection We recommend that the suggested office be a staff office to the Director, IE, headed by a GS-16/17 (or equivalent), who would be accorded equal rank with the other'IE Division Directors. We believe the proposed office should have a staff of at least one senior member from each of the program Divisions, plus individuals able to handle problems in administrative areas (i.e., moving expenses, personnel actions, etc.). The office should have full authority for the technical inspection program prescribed to be carried out by the resident inspectors, as well as the responsibility to monitor and evaluate the implementation of the resident inspection program.
We believe that centralizing these functions is necessary because, as the resident in:pcction program continues to expand, the fragmented structure now in existence (each Division has some responsibility) will not be adequate.
FY 1979 IMPLEMENTATION OIA has noted that IE fell short, by nine sites, of meeting its implementation goal for having inspectors in place at 49* reactor sites, by September 30, 1979.
IE has informed us that as of September 30, 1979:
- The number of reactor sites is actually 48 because Three Mile Island was manned with a resident inspector in FY 79. The number also includes resident inspectors at two fuel facilities.
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5 39 reactor sites had residtqt inspectors in place; 7 reactor sites had inspectors selected, but not yet in place; and 2 reactor sites did not have resident inspectors selected.
Table I shows, by region, the number of resident inspectors onsite as of
- i September 30, 1979.
TABU. !
RESIDENT REACTOR INSPECTORS ONSITE 9/30/79 REGION OPERATIONS CONSTRUCTION TOTAL I
6(1) 2(1) 8(2).
II 9(3) 2(2) 11(5)
III 8(1) 1(1) 9(2)
IV 2
2 4
V 3
3 6
Totals 28(5) 10(4) 38(9)
( ) above shows number of inspectors planned for FY 79, but not in place as of September 30, 1979.
We have been informed that of the nine reactor sites not covered in FY 1979, three reactor sites will have resident inspectors by December 31,1979, two by March 31, 1980, two by June 30, 1980, and two sites do not yet have scheduled dates for resident inspectors to be assigned.
DIA does not view the fact that IE fell short of its implementation plan as a.real problem, primarily because resident inspectors had already been selected for seven of the nine reactor sites.
To date, IE has relied on
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volunteers to staff resident sites instead of directed assignments, and this may have contributed in part to the delay in implementation.
Our concern, however, is that this failure to meet planned implementation goals might be indicative of problems that will be encountered in the future as the program expands and manpower resources grow even tighter.
With the approval of the " unit" inspector program, expansion of the resident inspection program has increased significantly.
Table II shows the original implementation schedule for the resident program.
6 TABLE II RESIDENT INSPECTION PROGRAM IMPLEMENTATION FY78 FY79 FY80 FY81 FY 82 Resident Insp?ctors 22*
49*
76 93 98
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- includes fuel facility resident inspectors As Table II shows, IE planned to have 93 resident inspectors in place at reactor sites by the end of FY 81.
However, with the recent Co:nmission approval to expand the resident inspection program, the previous implementation schedule has been altered.
The revised implementation schedule is shown in Table III.
TABLE III REVISED Ir*PLEMENTATION SCHEDULE RESIDENT INSPECTION PROGRAM FY78 FY79 FY80 FY81 FY82 FY 83 Operations Resident Inspectors 15 33 134 11 6 161 169 Fuel Facility Inspectors 2
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Con <.ruction Resident I.is pec tors 5
14 18 22 22 25 Totals 22 49 154 174 185 196 As shown in Table III, the resident inspection program has been expanded by 78 inspectors over previous FY 80 plans and by El inspectors over previous FY 81 plans.
At this point in time, DIA seriously questions whether IE can recruit, train and st& tion at reactor sites 78 new inspectors to meet the FY 80 goal.
We are concerned that the " quality" of inspectors will be sacrificed to meet targeted goals.
RESIDENT INSPECTION PROGRAM ACCOMPLISHMENTS In the course of our review, we have attempted to identify what the resident inspection program has accomplished and what effect the resident inspector.has had on the overall NRC reactor inspection program.
For the I
7 sake of simplicity, we havc grouped the program results into two categories:
those that are of an intangible nature, and those that can be quantitatively measured.
Infonr *
- on the intangible program results was obtained from discussions with.icensee officials, regional management officials, and To quantitatively analyze program results, we reviewed resident inspectors.
data obtained from IE's management infonnation system.
a Intangible Program Results Our review disclosed that both licensees and the NRC perceive several Principally, these include:
intangible results from the resident program.
increased familiarity of the plant by the resident inspector; better communication with the HRC; and a pennanent NRC contact person at the F.enerally, licensees and NRC representatives believe that the site.
resident inspector has an increased knowledge and familiarity of the plant The licensees conmented that as compared to the region-based inspectors.
the resident inspector's adaed familiarity with the plant and daily operations is beneficial, because it saves time on the part of utility management-having to escort inspectors around the site and in training or orienting region-based inspectors (since this function is assumed by the They also believe that the resident inspectors increased resident).
familiarity of the plant allows the inspector to understand the " nuances" that are unique to each individual plant. The licensees stated this helps to facilitate inspections performed by the resident.
NRC regional officials commented that the resident's increased familiarity with the plant, procedures, and management affords a more detailed and comprehensive understanding of both the plant and the capabilities of management running the plant.
Resident inspectors believe they get more exposure to the plant and its operating systems than they would as region-based inspectors. They also believe that with more expendable time onsite, they tend to feel less rushed in their inspection effort and thus have more opportunity to interface They believe this has ultimately improved the with plant management.
quality and substance of the noncompliances that are being found.
The licensees believe thdt the resident's increased availability and accessibility facilitates and expedites communication with the NRC (both IE and Licensing), although they note no significant change in the amount of communication with the HRC. The licensees also commented that, because of increased accessibility and better communication, the resident inspectors have been helpful in interpreting regulations or reviewing plant procedures to identify potential problems faster than could be done by going directly to the Region or to flRC Headquarters.
From NRC's perspective, regional management officials commented that the resident inspection program provides a qualified inspector onsite who can respond quickly to unexpected events and provide NRC with an independent account of plant operations and utility perfonnance in the event of an unusual occurrence.
8 Aside from these advantages, the only real benefit licensees perceive from the resident inspection program if that it has helped improve public perception of the plant. However with respect to plant safety, neither the licensees, NRC management officials, or resident inspectors feel that the program has significant1j imcmved the safety of nuclear power plants.
or that the resident inspector's presence onsite will preclude another accident such as Three Mile Island (TMI).
Recent incidents at two reactor sites which have h?C resident inspectors demonstrate that the resident inspector cannot pi vent an incident from occurring.
Some NRC and licensee officials commented that the resident inspection program provides no more direct inspection time than the former region-base program and has not affected the overall quality of inspection, with t' e exception of reduced
" nit picking." However, some NRC and utility officials we talked with believe that the resident inspector's continual presence onsita helps keep the plant management and staff more alert to little details, which will ultimately improve utility perfonnance and enhance plant safety.
Licensees, IE management officials, and resident inspectors had the following additional comments regarding the resident inspection program:
The resident inspection program has not improved the quality of inspection; overall, we are achieving the same quality of inspection but using more inspectors to accomplish it.
The resident inspection program is creating a lack of uniformity in the inspection program because each site becomes a unique blend of the resident inspector, the region, and the utility.
Because some amount of direct supervision is lost, the resident will tend to spend time in module areas that interest him.
It will be up to management to make surc that the resident diversifies his inspection effort.
Resident inspectors feel tnai. i.he nature ci the job causes them to take a somewhat reactive approach to the'r work, each day looking at what is going on at the plant, and that they must learn to allocate their time advantageously betwee a routine activities and special events.
Resident inspectors tend to find most items of noncompliance in areas not addressed in the inspection modules.
Residents generally feel they should not be restricted to the modules and should have more free time to flow with the activities at the site, though some program structure is desirable.
By working exclusively cnsite, the resident inspector loses the day-to-day contact with peers and rapport with regional management that is desirable.
Over time, this could promote tunnel vision or cause one to lose his sense of perspective.
There is a general feeling among resident inspectors as well as IE regional management that the resident inspection program has lacked Headquarters management attention and that IE needs to better define what it wants to accomplish with the resident inspec?. ion program.
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Quantitative Accomplishments _
In making our evaluation, we supplemented licensee, regional management, and inspector comments with quantitative data to show, in more measurable tenns, what the resident program has accomplished.
We extracted data on inspection hours and noncompliances (by both resident and region-based inspectors), from two sources--the weekly Manpower System (MPS) cards filed by the inspectors and the data from the 766-Form (which inspecto s prepare at the completion of each inspection). While we recognize that this data does not always accurately reflect how inspectors spend their time, it is the only data available for evaluation purposes and represents IE's official record of manpower utilization.
In developing the resident inspection program, it was anticipated that the resident inspectors would achieve more "onsite" time and more direct inspection effort than the region-based inspectors.
IE management set a goal of 54 percent direct inspection effort, meaning that the inspector was expected to spend 54 percent of his available time inspecting.
To detennine if this inspection goal is being met, we analyzed data from IE's management infonnation system for the five-month period November 1978 -
March 1979.
This period of time was chosea for two reasons:
(1) nost of the first group of resident inspector s were onsite by November 1978; and (2) the routine inspection program was significantly hampered as of March 31, 1979, with the incident at THI.
We believe this five-month period provides a representative picture of what the resident program has accomplished in its early implementation. The results of our analysis (Table IV) show that the resident inspectors are close to achieving the goal of 54 percent direct inspection effort.
TABt.E IV RESIDENT INSPECTORS DIRECT INSPECTION EFFORT Number of Resident Number of Insp.(1) Total Num. of Hrs.(2)
Percent of Time Sites Exanined Hours Reported Avail. for Insp.
Spent on Dir. Insp.
l-19 7,158 14,816 48%
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(1)
Information taken from Fonn-766 inspection infonnetion; includes overtime
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hours reported.
i (2) We detennined that there were 104 avaiLble workc'ays during the five-month period, for a total of 832 man hours per site (104 days x l
l 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />).
Adjustment was also made for when the resident inspector reported to the site.
The figures do not include overtime hours.
9 10 The above tabulation shows that the resident inspectors are averaging 48 percent of their time on direct inspe.ction effort, with an individual range of 29 to 104 percent of available time being spent on direct inspection e f fort.
It should be noted that our analytical method, i.e., including overtine in the total nunber of hours reported, makes it possible to achieve greater than 100 percent direct inspection effort. We did not include an overtime factor in the total number of hours available for inspection because a standard amount of overtime is neither authorized nor J
recognized. We anticipate that if this information were included into our analysis, it would tend to lower slightly the percentage of time spent on direct inspection effort.
We received several explanations from regional officials and resident inspectors regarding the wide variation in direct inspection effort.
These explanations include:
Lack of clear instruction by IE management regarding how time should be reported. Much of the inspectors' time is free floating and does not fit the 8 a.m. to 5 p.m. mold, yet the inspector is required to force his time to meet timekeeping requirements.
Inadequate guidance regarding th'e role of the resident and how his time should be allocated between various duties.
Too much attention devoted to regional and administrative matters due to lack of secretarial / clerical support, as well as time consumed by training / orienting regional inspectors, etc.
Interfacing with plant management and other interruptions onsite which decrease the time available for direct inspection effort.
The resident program has just gotten underway at many sites and it takes a while to get it running smoothly.
Many of the problems that surfaced in the initial stages were hard to anticipate and have since been resolved.
He believe that, to some degree, all these factors contribute to the resident inspector not being able to achieve 54 percent direct inspection effort.
We also compared the number of noncompliances found by resident inspectors versus region-based inspectors. Table V shows the number of noncompliances and inspection hours, by resident and nonresident inspectors, for those reactor sites which tave an NRC resident inspector.
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e 11 TABLE V ItiSPECTION HOURS PER NONC0!!PLIANCES_
RESIDENT AND NONRESIDENTS _
No. of Noncompliances No. of Insp. Hrs._
Hrs./ Noncom 51 7,158 140.35 Resident Inspectors
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Nonresident Inspectors 186 11,598 62.35 As shown in Table V, resident inspectors, on the average, found an item of noncanpliance every 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br />,' while region-based specialist i.,spectors found a noncompliance every 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br />. Although OIA recognizes that the number of noncompliances is not necessarily indicative of progra.n effectiveness, we found that this disparity has been the cause of sone concern to IE Headquarters and regional management.' The significance of this disparity is not apparent and suggests that this nay Ne a possible area for further study by IE management as an unresolved issue in the resident inspection program.
Several possible explanations have been offered as to why region-based inspectors are finding noncompliances at nearly 2-1/2 times the frequency of the resident inspectors. These include:
The "C" level inspection program stresses observation of work and surveillance testing rather than review of utility records.
Historically, however, most noncompliances have been found in the course of records review, which is part of the focus of region-based inspectors.
Resident inspectors practice preventive noncompliance by bringing to plant management's attention potential problem areas before they turn into noncompliances.
Residents are aware of mitigating circumstances at the plant that Also, the resident has more region-based inspectors ray not know of.
tine available to research out a suspected noncompliance before it is written up, so that in soine cases a noncompliance does not result.
In specialized areas where he may lack expertise, the resident inspector will steer the rc7 on-based specialist into areas where a i
problem is suspected.
To preserve an effective, hannonious relationship with plant management and avoid taking on an adve sary role, the resident may direct region-based inspectors to cite a noncompliance actually found by the resident.
f
12
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With the "C" level inspection program, the resident is attempting to accomplish tco much with limited resources, i.e., the resident is spreading himself too thin.
Time reporting methods are not consistent between residents and region-based inspectors, or among residents themselves, which means that the base (number of inspection hours) fe incongruous for purposes
,of comparison.
It should be noted that noncompliances are significant only in terms of how they relate to plant safety and that not all noncompliances necessarily relate equally to plant safety. As such, it is difficult and, to some extent, unrealistic to compare mere numbers of noncompliances.
DIA recognizes this fact and has attempted only to compare the relative frequency of-noncompliances as a measure of program performance. We have not looked at the safety significance of the noncompliances found.
Another goal of the resident inspection program is to provide an increased amount of inspection effort at reactor sites.
To detennine if this program goal is being met, we attempted to analyze the amount of inspection effort at selected resident sites and comparable nonresident sites, for the five-month period November 1978 thru March 1979. However, because the data we received from IE management information system was incomplete, we were not able to determine if this program goal is being met. Table VI shows some of the data we received from the IE management information system.
TABLE VI RESIDENT INSPECTION HOURS No. of Resident's Nov.
Dec.
Jan.
Feb.
Mar.
Reactor Site Units First Date 1978 1978 1979 1979 1979 Dresden I, II, III 10-02-78 172 104 95 85 112 Millstone Pt.
I, II 11-05-78 85 72 68 74 Indian Pt.
II, III 09-27-78 55 42 60 36 120 32 99 Browns Ferry I, II, III 11-20-78 Oconee I, II, III 12-17-78 NA 65 129 84 16 Salem I, II 07-10-78 27 140 182 Surry I, II 12-17-78 90
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Prairie Island I, II 09-05-78 152 133 101 42 130 DC Cook.
I, II 1974 107 63 128 164 Hatch I, II 12-10-78 NA 205 63 50
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Trojan I
08-13-78 50 105 77 57 84
13 As shown in Table VI, the computer file showed no resident inspection hours in March 1979 for five resident inspectors who entered en duty prior to'1979.
The file also shows only 43 inspection hours, for one inspector, for the entire five-month period. IEimerous other discrepancies exist elsewhere.
OIA has also found that data for resident inspector manhours reported in NRC's itanpower Reporting System (MPS) was so incomplete as to be useless for management analysis purposes.
Because of this lack of credible data, 01A was not able to detemine if the resident inspection program has, in fact, resulted in an increased amount of inspection activity over the inspection effort at nonresident sites.
It was explained by IE representatives that the incident at TMI and the resulting NRC response may have delayed the entry into the computer system of inspection-related information. While this may be a plausible explanation, most of the data we requested covered the period and was generated prior to TMI. Also, the infomation we used was contai.,ed in a computer printout dated June 15, 1979.
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We believe that it is imperative for IE management to have complete and accurate data in their management infomation system in order that proper management decisions regarding the implementation of the resident inspection program can be made. Without accurate computer infomation, we believe that IE management will be hampered in their evaluations of the resident inspection program.
While the resident inspection program may be close to, or achieving its goals, the overriding concern is still the safe operation of the reactor.
Both licensee and IE officials agreed that the stationing of a resident inspector at a reactor site will not.make that site safe. fiost officials we spoke with believe that having a resident inspector at the reactor site will enhance safety, although it is not possible to detemine by how much.
Several licensee officials indicated that they do not believe their plants are any safer because tne NRC resident is there. These officials also indicated that they have noticed no difference in the inspection program or quality of inspection since the residents were assigned to their reactor sites.
Recomrendation 2 We recommend that the Director, IE, develop an action plan to ensure that the IE management infoma tion system is both producing accurate, reliable infomation, and is being used to evaluate program accomplishments. As a minimum the action plan should provide that:
the MPS and Fom-766 data files be reviewed to detemine where discrepancies are occurring, and that steps be taken to alleviate the problem; i
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4 14 a periodic review (i.e., weekly, r:onthly) be r:ade of the data entered into the mangenent infomation system in order to verify the accuracy of such infomation; and IE management determine what i+ mation is needed to evaluate the accomplishments of the reside..
inspection program and start generating this infomation from the management infomation system.
P,0LE OF THE RESIDENT IfiSPECTOR DIA has found that, to date, no uniform policy exists clearly defining the duties, responsibilities and authority of the flRC resident inspect 's.
This would include what the resident inspector is expected to do on a daily basis, as well as during an emergency at the site.
Licensee officials we spoke with indicated they would like to see this area clarified by the NRC. He also found that there is no fomal regulatory requirement for the licensee to notify the resident inspector in the event of an emergency at the site.
In light of the incident at T!11 it is imperative for the resident inspector to have a clear understanding of his responsibility and authority at the site. The resident needs to know what is expected of him on a daily basis and how to respond during an incident at the plant.
During an emergency, he needs to know whei.her to act as a communications link to the NRC, be in the control room, offer advice to the licensee, or function in some other capacity.
What makes a unifom policy even more important is the concept.of the resident inspection program itself.
It has long been an NRC premise that the licensee is responsible for the safe operation of the reactor, and for operation of the reactor during emergency situations.
The licensees we spoke with believe that, by being licensed by the NRC, it is their responsibility and not NRC's, to operate the reactor during both routine and emergency situations.
Representative comments made by licensees included:
"During an incident, the resident should stay out of the way and not be involved except as an observer. The utility should have responsibility for a plant during an incident."
P "Regarding the role of the resident in an emergency, all our emergency procedures are designed for us to respond to, and run the incident.
I believe the NRC resident should have an advisory and communications role during the incident."
The licensees believe that, because the NRC resident inspector is not a
" licensed operator" for the reactor to which he is assigned, their operators have a better knowledge of how to or ate th' reactor during routine and and resident inspectors emergency conditions.
IE regional i share this concern. They believe the
+ ent inspector should not interfere or try to operate the plant au.
. emergency.
i e
i 15 In an attempt to define the " role" of the resident inspector, several of the regional offices have issued resident inspector's handbooks.
- flowever, this has resulted in a somewhat non-unifonn approach to defining the
" role" of the resident inspector. One region has indicated that during a site emergency, "the resident will n'plement onsite aspects of the regional Emergency Response Plan." Other regic9s believe.that the resident should establish and act as a communications ling during an cmergency.
The same type of disparity exists with respect to netifying the resident inspector of an energency at the reactor site. He were not able to find any regulatory requirement committing the licensee to notify the resident inspec';r in the event of an energency at the site. We were informed that, in many cases, the resident inspector has worked out an informal agreement with the ifcensee regarding notification of an unusual or emergency situation.
The need for the resident to be promptly informed has been demonstrated recently with unusual incidents occurring at several reactor sites.
To help alleviate these disparities, in November 1978, IE issued " draft" Manual Chapter (MC) 1215 dealing with the resident inspection program.
Concerning the role of the resident during mergencies/ incident, the proposed MC states:
"Your role is to be a liaison with the licensee and to carefully monitor the licensee's response. Do not participate in the licensee's response..."
Other sections of the proposed MC deal with the authority of the inspector and what his daily duties and responsibilities are. The proposed MC states that the resident is the " eyes and ears" of the NRC in the field.
It also indicates that the resident may be called on to deal with the media, local officials, the public and licensee employees, but these dealings should, whenever possible, not interfere with the performance of the inspections.
Recommendation 3 Ue recommend that IE establish a uniform policy detailing the duties, responsibilities and authority of the resident inspector at reactor locations.
The policy should indicate, much as the proposed IE MC does, what is expected of the resident inspector on a daily basis and how the resident is to respond during an emergency. We also recommend that NRC develop and
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implement criteria requiring the qotification of resident inspectors in the event of an unusual occurrence at the reactor site.
"C" LEVEL INSPECTION PROGRAM Our review disclosed that regional management officials, resident inspectors and licensee officials believe the "C" level inspection program needs to be reevaluated and restructured to achieve an inspection program that is
a 16 both efficient and reasonably achievable. Most regional management officials and residest inspectors we spoke with believe that the "C" level inspection program is 100 complex to be performed in total and that, in many instances, it misdirects the inspection effort.
Licensees we spoke with commented that they have noticed no appreciable change in the inspection program since resident inspectors were assigned to ti,eir reactor sites.
In implementing the resident inspection program, IE developed the "C" level inspection program, designed to be performed by the resident inspector.
The "C" level program is intended to provide NRC with more direct observation of surveillance testing, construction work, and licensee activities.
This is in addition to the "B" level inspection program performed by the region-based inspectors.
Most of the resident inspectors we spoke with expressed dissatisfaction with the way the "C" level inspection program is written.
While the inspectors agreed that some form of structured inspection program is necessary, they are almost universally negative about the "C" level inspection Generally, the complaints are that the "C" level inspection program.
program is too complex to be accomplished completely and that it doesn't allow the resident inspector to take advantage of the unique opportunities afforded by his being onsite.
The "C" level inspection program was discussed at a turch 1979 meeting of resident inspectors, where a task group of inspectors was assigned to briefly evaluate the inspection program.
The task group's general comment on the inspection program was that NRC "took something bad and made it worse." Other comments mada included:
" Program requires more time than is available.
Headquarters estimates are about 1000 man hours.
1800 to 2000 appears to be more realistic."
" Program needs flexibility to be site specific and to deal with site problems."
The task group concluded their brief evaluation by making the following recommendations (for "C" level inspection modules):
" Discard the present ones and rewrite the green pages to take advantage of unique potential of the resident. The modules serve a good function in keeping an inspector from only inspecting areas of interest while other areas are going to pot."
DIA was informed that, at the March 1979 meeting, the then IE Director made a commitment to reevaluate the "C" level inspection program in light of the resident inspectors' comments.
However, subsequent to the March meeting, the incident at TMI occurred, delaying the reevaluation of the "C" level inspection program.
17 OIA noted that each regional office is taking a somewhat different approach in implement'ing the "C" level inspection program.
This is causing a lack of unifomity between and even within regions in implementing the inspection program. One region has rewritten the inspection program (by reducing inspection frequencies) to coincide with the amount of inspection time available to the resident inspector.
Other regions are allowing their residents to rewrite the inspection program as they perfom it at their particular facilities.
Still, other regions are not altering the inspection program at all and are trying to perfom the program as written. This lack of unifomity could cause difficulty in making a neaningful evaluation
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of the resident inspection program because a homogeneous inspection base will not exist.
Several licensees we spoke with expressed disappointment that the itRC was not using the resident inspector to tailor the inspection program.to their particular site. A representative comment'was:
"The tiRC should use the resident inspection program to custom fit the inspection program to each utility.
Otherwise, it is a waste of time to inspect each reactor site the same."
Generally, the licensees indicated that they have not noticed any real difference in the quality or quantity of inspection perfomed by the resident inspector versus that perfomed by the region-based inspector.
Recommendation 4 lie recommend that IE reevaluate the "C" level inspection program to develop a fully integrated inspectio'n program that is acceptable to the resident and region-based inspectors, and IE Headquarters 'and regional management.
This is important because, with the advent of " unit" inspectors at each site, the resident inspection program will become the cornerstone of the reactor inspection program.
It is imperative that the inspection of the unit inspection program (recently approved by the Congress)plem program for resident inspectors be fully developed prior to the im DEVELOPI'ENT OF A CAREER LADDER During our review we noted that a fomal career ladder has not been developed as called for in the implementation of the Revised Inspection Program. This is resulting in uncertainty among resident inspectors as to what they can expect in their career progression at the conclusion of their resident tour of duty.
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18 In flVREG-0397, Revised _ Inspection Program for fluclear Power Plants (f' arch 4
1978), IE management stated that a resource management system would be developed, and that:
"A comprehensive career plan will provide guidance for the professional development of employees and will describe career opportunities for both horizontal and vertical career progression."
OIA found that, even as increasing numbers of inspectors are being assigned to reactor sites, no foma1, structured career ladder has been developed.
I At the present time, no policies exist delineating the optimum length of time for a resident tour of duty (three to five years is the current thinking of IE officials); the number of resident tours which may be required of an individual inspector; whether a tour through headquarters will be required; and whether or not an inspector will be returned to his/her home region at the conclusion of a resident tour.
IE's development of a formal career ladder may have been complicated by the commitments made to the first group of resident inspectors by the Director, IE. A letter from the former IE Director stated that these inspectors would be allowed to return to their home region upon completion of their resident assignment. The letter states that:
"The length of a resident tour is a nominal three years.
The three years commence when you move to a site... Tours may be extended or shortened at the discretion of IE and the consent of the inspector....
You will be returned to your home region at the conclusior, of your tour of duty, if that is your preference. Assuming satisfactory performance, you will be considered for other lateral transfers within IE with preference over nonresident inspectors."
At the present time it is unclear whether these commitments will be honored by the current IE management.
If so, this could effectively remove these qualified inspectors from _the resident program in 1982 unless some of these individuals volunteer for another resident assignment.
The regional management officials and resident inspectors we spoke with believe that a career ladder should be established and coordinated with the implementation of the resident program.
Also, most of the inspectors we talked with expressed the same concerns noted above, especially with respect to the number of resident assignments that would be required and whether they could return to their home region at the conclusion of the resident assignment.
Several resident inspectors indicated that they might be interested in serving a second resident assignment, but that before they would volunteer, the policy concerning career advancement would have to be clarified.
Recommendation 5 We recommend that IE management develop a formal, structured career ladder as indicated in flVREG-0397. We believe this career ladder should answer the concerns we have noted in this section, and that program o
f
t 19 implementation should be consistent with the expanded inspection prooram concept of nultiple inspectors at reactor sites. He believe that failure to develop a career ladder in a timely manner will only tend to detract from the morale of the existing inspection force and possibly adversely affect future progran implementation and effectiveness.
SEl.ECTION CRITERIA FOR RESIDENT IflSPECTORS Our review disclosed that there were no unifonn criteria concerning the qualifications needed for the selection of resident inspectors.
The selection of resident inspectors to date has been done by using "draf t" criteria, which have not yet been approved by the National Treasury Employees linion (NTEll). The criteria being used were transmitted in a menorandum dated February 13, 1979, by the then IE Director, to the five regional offices.
Since that tine no finalized criteria have been established or implemented.
When the resident inspection program was initially implemented, the policy was to select the most highly qualified, senior (experience) level project inspectors to be resident inspectors. This policy, which assumed qualified inspectors would volunteer to be resident inspectors, was followed by all five of the regions during initial implementation of the resident program.
01A has noted that as program implementation continues, disparity among the regions increases as to who is selected to be a resident inspector. We were told by some regional officials that they still consider the selection criteria to be that the most qualified senior level inspector should be chosen to be a resident inspector.
Other regional officials indicate that they consider the resident assignment to be a hardship, so they select qualified inspectors with least seniority to be resident inspectors.
Licensees also commented to us on the qualifications they perceive are needed by a resident inspector. The consensus among licensees was that a resident inspector should be an experienced, technically qualified individual.
Several connents 0IA received included:
"Our resident inspector is technically competent and extrenely knowledgeable, has a broad ranne of thinking and can address most issues and areas.
The resident is easy to communicate with and he is a realist, who can put things into perspective.
"I believe that the resident inspector must be a generalist and must possess operations and inspection experience, good communication skills and maturity."
9 20 Generally, the licensee officials we spoke with believe the success or failure of the resident program is dependent on the quality of the inspectors assigned to reactor sites, as evidenced by the following comment:
"The success of the program to date is partly due to the high calibre of individuals selected to be residents.
Centinued success will be dependent on selecting the most professional ad technically qualified inspectors to be residents."
The licensee uficials believe the current NRC resident inspectors are competent to perfonn their duties and that this type of individual should continue to be selected as an NRC resident inspector.
Lack of finalized selection criteria for resident inspectors holds' flRC management open to criticism by IE inspectors and the flTEU.
To date, inspectors assigned to resident sites have been volunteers, although some have been reluctant volunteers.
As program implementation continues, the possibility of not having a volunteer for every resident site increases.
Several regional officials have indicated that the lack of selection criteria has, to sone degree, hindered the implementation of the resident program. They indicated a fonnalized policy is necessary as the resident program continues to expand.
Recommendation 6 We recommend that IE management develop unifonn finalized criteria for the selection and assignnent of. resident inspectors. We believe these criteria should be consistent with the technical and career development aspects of the inspection program.
ADMIT:ISTRATIVE pR0BLEf1S Administrative problems recognized before the adoption of the resident program remain unresolved more than a year after initial implementation and nay be no closer to satisfactory resolution. These include assignment and use of Government vehicles, reimbursement for all reasonable moving expenses, and onsite clerical assistants.
Government Vehicles
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The issue of providing Government automobiles for the resident inspectors arose because of the isolated location of many reactor sites.
In many cases, due to the lack of suitable housing in close proximity to reactor sites, inspectors noving to reactor sites face longer commuting distances than they did in the regional offices.
Because IE tic 0237 prohibits resident inspectors from using carpools with licensee personnel, he is
21 required to use his own transportation to commute to work daily.
Several resident inspectors indicated that becoming a resident inspector has necessitated the purchase of another automobile which has compounded the financial burden of moving to the reactor site. Other resident inspectors indicated that they would not use personal automobiles to take site tours, as necessitated by the resident program, due to the rugged conditions around most reactor sites (especially construction sites), or to go to the local post office to pick up their mail.
This is required because NRC does not allow the resident inspector to use the licensee's mail channels.
IE requested the NRC's Office of Executive Legal Director (ELD) to provide a legal opinion concerning the feasibility of providing NRC resident inspectors with Government cars.
The opinion, dated November 22, 19.78, states:
... Based on our research and consultations with the General Accounting Office (GAO) and the General Services Administration (GSA), we have detennined that resident inspectors may use Government vehicles for official purposes only.
There is no authority for the inspectors to use Government vehicles for transportation between their homes and their official duty stations and the licensee sitee."
ELD concluded that:
...in general, we would not consider it appropriate for NRC to authorize an employee use of a Government-owned vehicle in other than an energency for the purpose of personal transportation between his or her residence and official duty station, even in connection with the perfonnance of additional work outside of regular duty hours."
The issue of resident inspector transportation is still unresolved at this
- time, IE has not yet developed a unifonn policy concerning this issue.
Several resident inspectors do have Government vehicles, although they are not to be used to commute between the inspector's residence and the reactor site. These automobiles are either stored at a local government facility or at the site, and are mostly used to take tours of the reactor site and to pick up mail at the local post office.
IE is also considering providing the resident inspectors with an emergency vehicle to be used to respond to incidents at, or around, the reactor site. The plans are to equip the emergency vehicle with equipment needed to respond to an incident, such as radiation monitoring equipment, protective clothing, and communications gear. The emergency vehicle would be available to the resident inspector at all times and would alleviate the need for a GSA vehicle.
Reimbursement of Moving Expenses Another area of concern to the resident inspectors is the reimbursement of moving expenses involved in relocating to the reactor site.
Reimbursement of moving expenses is governed by the Federal Travel Regulations, by which
r v
22
!!RC is bound. These regulations do not provide reimbu'rsanent for all expenses incurred in noving.
Resident inspectors have indicated tliat they have taken a financial loss due to moving to a resident site. During their March 1979 necting, a task force of resident inspectors summarized their relreation experiences as follows:
" Moving--very costly plus many problems experienced.
Need more efficiency, better arrangements, quicker reimbursements."
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"Estinate average first year loss of $5,000-$15,000.
Need some way to help defray this."
Several resident inspectors we spoke with indicated that if they were forced to take a large financial loss every time they relocate, that they
- would not be able to move between resident sites.
Individual comments from resident inspectors concerning reimbursement of moving expenses included:
"This is the largest single problem area with the resident proqram and it is spelled HONEY.
My estinate of moving related expenses and use of private auto for first year add up to over $18,000 not reimbursed by NRC...
I moved nany times in the military but recent inflation and mortgage interest rate increases made this move much more difficult than all the other moves."
"The !!RC should request Congressional action to allow for reimbursement of expenses which are now excluded (i.e., loan discount points, nortgage insurance, etc.) and for purchasing and selling houses which cannot be sold within prescribed time limits."
In a memo dated June 21, 1979, to the EDO, Commissioner Ahearne stated:
"In particular I an concerned that we more rapidly address the nuestion of financial loss faced by people going into the resident inspector program.
As you and I both know from our military tours, it is extremely important to he able to provide at least some neasure of protection regarding moving.
I suspect that the NRC, being both new to the business of moving people and also having very few people being noved, has not had the opportunity to develop that type of systen.
I renew my request that we consider the possibility of utilizing the military system for our noves and also strongly endorse any appropriate legislativa language that would enable us to put into place such measures as paying the differential for loss of housing y lue, paying visitina expenses for a family to ao set up in a new area, and providing an NRC car for an NRC inspector."
t
23 He were infomed that the Travel Services Branch (TSB), Office of Administra-tion, has prepared a folder containing documents and instructions concerning relocation and movement of household goods.
The folder is now given to resident inspectors prior to their move.
Inspectors generally have had favorable comments about the contents of the folder and the helpfulness of the personnel in the TSB. However, the inspectors felt that just having a copy of the travel regulations did not necessarily nean that they understood them.
The inspectors believe that a seminar would be helpful, where the l**
TSB could help interpret the regulations and identify pitfalls to avoid.
We noted that 'IE management has looked inte (inding ways to reimburse resident inspectors for real_ monetary losses incurred in noving to resident sii.cs. These neasures include having an exemption made in the travel regulations for the relocation of resident inspectors, premium pay for the inspectors to make up for financial losses, and overtime pay. To date, no fim proposal has been decided upon to help reimburse inspectors for monetary losses incurred in moving to resident sites.
We understand that the resident inspection program " coordinator" is in the process of collecting detailed information from each resident inspector on the costs involved in their relocation.
This information is expected to be compiled by early 1980.
OIA is concerned that if inspectors continue to experience significant monetary losses in moving to, or between reactor sites, it will hamper the continuing implementation of the resident inspection program.
Clerical Assistants The third administrative problem area concerns the use of clerical help for the resident inspectors. !!any of the resident inspectors we spoke with indicated that use of a part-time clerk or secretary would relieve them from some of the paperwork and allow more time to perform inspections.
During our review OIA noted no consistency in the provision of clerical assistants to resident inspectors.
Several resident inspectors we spoke with indicated they did have part-time clerical assistants and that this had a significant impact on the amount of time they had to perform inspections.
Other inspectors indicated that they did not have any clerical support aad were told that they would not be allowed clerical help.
However, IE management has been allocated the necessary resources, and CIA's understanding is that resident inspectors who request clerical assi-tants will be given pemission to obtain a part-time secretary.
Also, those resident inspectors that do have part-time clerical assistants complained that their clerical help had to obtain'a security clearance before they could work for NRC.
The residents contended that it is unreasonable to expect a potential employee to wait 3-6 months for a security clearance just to work 10-15 hours per week. While it is possible to request a security clearance waiver for new employees, regional offices indicate it still takes 3-4 weeks to obtain a security clearance waiver. The residents also believe that the isolated location of some reactor sites makes it unattractive for someone to work just part-time.
24 P
OIA is also concerned that with the advent of the Expanded Resident Inspection Program, part-time clerical help may no longer be adequate.
Most reactor sites will have at least 2-3 inspectors, and we believe this may warrant a full-time clerical assistant.
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Recommendation 7 He recommend tha+ NRC management take more agressive steps to resolve the three administrative problems noted above by:
(a) Developing and publishing NRC regulations governing the assignment and use of governnent vehicles by IE resident and region-based inspectors.
These regulations should be supplemented by NRC' Regional Office Directives as appropriate to be site specific when deemed necessary; (b) Using the information gathered from the proposed resident inspector survey to either develop a legislative proposal for the submission to the Congress to provide authority for the payment of reasonable relocation expenses irrespective of the limitations of OMB Circular A-56 which governs the payment of moving expenses for government employees, or finding alternative methods to reimburse resident inspectors for all reasonable relocation expenses; and (c) Developing a uniform policy for providing clerical assistants to resident inspection sites, and also examining the feasibility of assigning a full-time clerical assistant to the resident sites.
OVERALL CONCLUSION _
OIA concludes that the lack of high level, contralized management for the resident inspection program has hampered program implementation. He believe that this lack of centralized management has resulted in many of the problems noted in this report. We also believe that the issues of (1) qualifications for resident inspectors, (2) defining the role of the resident inspector, (3) development of a career ladder, (4) reevaluation of the "C" level inspection program, and (5) problems in the administrative areas, are indicative of a general lack of management attention by IE Headquarters officials to the implementation of the resident inspection We believe that proper planning pr for to and in the early program.
stages of implementing the resident inspection program would have alleviated many of these problems. We also believe that failure to address these problems in a timely manner will tend to exacerbate them, as the resident program is to be greatly expanded in the next two years.
l
25 While we are aware that IE has appointed an individual to act as a resident
" coordinator," we believe this action is not only long overdue but also insufficient to resolve the problems we have identified.
The resident
" coordinator" does not have the authority to implement any of the tasks under study, but rather, has to deal with the appropriate Division Directors to get the work performed. Although the appoindnent of a resident " coordinator" has tended to centralize some responsibility in one person, we still believe that this is not an adequate solution. The expanded resident inspection program is becoming, for all intents and purposes, the major NRC reactor i
inspection program, and we do not believe one person can be responsible for implementir.g and resolving the problems associated with the program.
AGENCY C0!!!!ENTS In responding to our report, the EDO generally agreed with our findings and recoraendations.
However, the ED0 did not concur with our recommendation to establish a separate IE staff office to oversee the resident inspection progran at the present time. The ED0 stated:
"The lack of centralized planning and information gathering on the Resident Inspector Program had been evident for some time.
IE recognized this problem and, in early August 1979, appointed a resident progran coordinator....I do not agree with OIA's recommendation that a separate IE division be established to direct the Resident Inspector Program....
I feel that the current arrangement where each IE division continues to exercise its unique functional responsibilities and a coordinator tracks their efforts to the needs of the Resident Inspector Program, is working well."
The ED0 further stated that: "Nevertheless, we will be considering the option of establishing a separate division as the program evolves."
Concerning the development of a career ladder, the ED0 commented that action is complete:
"A contractor, General Research Corporation, developed a career ladder structure for IE in flarch 1979. The " unit" inspectors are fully integrated into this structure and can expect to advance to senior resident inspectors, Regional or performance appraisal inspectors, and
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junior Headquarters assignments.
Senior resident inspectors
. e can advance to positions as Regional section and branch chiefs or to senior Headquarters assignments."
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26 01A COMMENT We have reviewed the career ladder structure developed by the General Research Corporation; however, it is not evident that IE has developed the type of comprehensive career ladder structure we intended. -The contractor made numerous proposals and recommendations, and OIA was unable to determine which of these were adopted.
As noted in the ED0 response, IE has not yet developed a policy on reassignment of senior resident inspectors after their tour of duty at a site is completed.
OIA does not consider action on e
this recommendation to have been completed.
The complete response, which explains the actions being taken on seven other DIA recommendations in which the ED0 concurred, is contained in Attachment I.
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7 Attachment I y.m, y,
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UNITED STATES
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p, NUCLEAR REGULATORY COMMISSION r C WASHINGTON, D. C. 20555
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gEc 161979 MEMORANDUM FOR: James J. Cummings, Director Office of Inspector and Auditor FROM:
Lee V. Gossick Executive Director for Operations
SUBJECT:
0IA DRAFT REPORT ON RESIDENT PROGRAM IMPLEMENTATION I agree generally with the recommendations of OIA's Draft Report, " Review of the Continuing Implementation of NRC's Resident Inspector Program." My specific comments on each of the nine reconmendations are as follows:
Recommendation #1: Establish a Separate IE Staff Office for Resident Inspectcr Program.
Non-concur:
The lack of centralized planning and information gathering on the Resident Inspector Program had been evident for some time.
IE recognized this problem and, in early August 1979, appointed a resident program coordinator. He was tasked with: (1) comprehen-sively planning implementation of all programmatic and adminis-trative elements relating to resident inspection; (2) assuming responsibility for those elements not assignable to a specific IE organization; (3) reporting on implementation and on how IE com-mitments were being met; and (4) maintaining contact with Regional supervision and with resident inspectors to assure that problems are quickly resolved. He reports periodically to the IE Director and, on nearly a daily basis, to IE's Deputy Director.
A comprehensive plan was approved in mid-October, 1979.
It incorporates the efforts of all IE Headquarters units, a number of other NRC offices, and specific Regional Offices.
It includes
.e action on recommendations made by 0IA. A monthly accomplishments report was initiated at the end of August.
It reports oi staff-and, since the end of October, on plan element completions. A comprehensive list of current commitments has been compiled and reporting on these is being incorporated into the monthly accom-plishments report.
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I do not agree with 01A's recommendation that a separate IE division be established to direct the Resident Inspector Program.
A separate staff can easily' result in duplication and interdivisional friction. These we can ill afford.
I feel that the current arrangement where each-IE division continues to exercise its unique functional responsibilities and a coordinator tracts their efforts to the needs of the Resident Inspector Program, is-workir.g well. Nevertheless,Toa will be consider-ing the option of establishinig a separate division as the program e
evolves.
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Recommendation #2: Develop Action Plan on 'IE Information Systems.
Concur.
OMPA has an IE request.to speed processing of MPS data.
This' includes developing an independent IE/MPS data base and preparing all necessary computer programs to maintain this data base includ-ing an edit program. OMPA expects to complete this task by March 1, 1980. This will speed data usage from a 3-month lag to 3 weeks or less. Meanwhile, an IE contractor will define the " products" and
" resources" data needs by February 1,1980.
Integration and imple-mentation of the two should occur by' April 1, 1980. The same con-tractor is developing (by April'1980) and testing (by June 1980) a comprehensive methodology for resident program evaluation.
Recommendation #3: Define Duties, Responsibilities and Authority of Resident.
Concur.
The scope of duties, responsibilities and authority for resident inspectors has been conveyed to these inspectors, primarily in their training program.
IE is formalizing these in the process of-reworking the inspection program. An IE Headquarters-Regional task force will define by February 1, 1980 the resident inspector's role in performing an integrated, Regional-and Resident-based, routine inspection program. The resident inspector's role in incidents will be defined by IE's Operations Support staff by December 31, 1979.
Recommendation #4: Develop a Fully Integrated Inspection Program.
Concur.
An IE Headquarters-Regional task force is developing an integrated routine inspection program for preoperational and operating reactors.
They are currently incorporating recommendations from the Lessons Learned and Kemeny Reports. They are expected to issue the integrated program before May 1,1980, about the time that the first " unit" inspectors complete their required training.
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, Recommendation #5:
Develop a Career Ladder.
Completed.
A contractor, General Research Corporation, developed a career ladder structure for IE in March 1979. The " unit" inspectors are fully integrated into this structure and can expect to advance to senior resident inspectors, Regional or performance appraisal inspec-tors,'and junior Headquarters assignments. Senior resident inspectors O
can advance to positions as Regional section and branch chiefs or to senior Headquarters assignments.
Recommendation #6: Develop Criteria for Resident Inspector's Selection and As,signment.
Concur.
All but one of the issues on selecting and assigning resident and senior resident inspectors have been resolved and necessary criteria
-developed'and finalized. These include position descriptions, training requirements, conflict of interest, supervisory relation-ships, and reassignment from Regional Office to resident sites. A policy on reassignments after a tour of duty at a site will be developed by May 1980.
Recommendation #7: Develop NRC Regulation on Assigning and Using Government Vehicles.
Concur.
A policy statement and procedure on assignment of government vehicles to resident offices will be issued by December 31, 1979.
It will covar the uses of such vehicles.
Recommendation #8: Develop Legislative Proposals or Other Means to Relieve Financial Burdens of Relocation.
Concur.
I have established a multi-office task force to develop legislative proposals for alleviating both the house buying / selling burden and
,o the limits of reimbursement for moving household possessions and families. The task force is to complete its efforts by January 31, 1980.
Recommendation #9: Develop a Policy on Clerical Assistants at Resident Sites.
Concur.
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' To the extent permitted by its ceiling and the availability of qualified candidates, IE will provide part-time clerical suppor+
for resident offices.
IE is encouraging the assignment of part-time clerical positions to resident offices. Most resident offices should have such assistance by September 30, 1980.
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'. Lee V. Gossick
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Executive Director for Operations
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