ML19341A537
| ML19341A537 | |
| Person / Time | |
|---|---|
| Issue date: | 06/22/1979 |
| From: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19341A503 | List:
|
| References | |
| FOIA-80-516 NUDOCS 8101260314 | |
| Download: ML19341A537 (15) | |
Text
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(gg/jj REPORT To THE commcascom s.....
W B U M DESDMAB3LE HFFECTS OF ACCEL 2MATDMG THE
.DMiPL2M 2RTATDOM OF M MC'S RSSDD2NT OWSP2CTD0M PROGMARil PdOTHCE This is an Internal Management Document Prepared For The Commission Not to Be Released Outside of NRC JUNE 1979 7
2.n OFFICE OF INSPECTOR AND AUDITOR U.S. NUCLEAR REGULATORY COMMg S nouso3 q LRe AtA-
pn nec UNITED STATES y.
g NUCLEAR REGULATORY COMMISSION g % w([A g WASHINGT ON, D. C. 20555 E
$ Jt %!kh,Y June 22, 1979 MEMORANDUM FOR: Chairman Hendrie Comissioner Gilinsky Comissioner Kennedy Comissioner Bradford Comi sioner Ahearne FROM:
s
. Cumm s, Directo
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ffic of Inspector and Auditor REPORT ON THE UNDESIRABLE EFFECTS OF
SUBJECT:
ACCELERATING THE IMPLEMENTATION OF NRC'S RESIDENT INSPELTION PROGRAM 1979, 01A began a self-initiated review of the Nuclear Regulatory Our Comission's (NRC) Resident Inspection Program for. re In March at reactor sites, determine what the resident program After the start of and Enforcement (IE) during initial implementation.
our review, the incident at Three Mile Island (THI) occurred, resulting in increased public and political pressure to assign resident inspectors In response at all operating and test and startup reactor facilities.to this in with an independent assessment of the problems and issues which might occur if an accelerated implementation of the Resident Inspection Program Attached is a copy of our report.
at reactor facilities is undertaken. Future OIA reviews wil Inspection Program.
Our review was conducted during the period March through May 1979 at N Headquarters and Regions I, II, III, and IV. Regional Directors We other IE officials concerning the Resident Inspection Program.
visited six resident reactor inspectors (three operations and three construction) to discuss the implementation of the Resident Inspection We also reviewed pertinent documents, studies, and computer Program.
data concerning the resident program.
Contacts:
H. Boulden, OIA M. Auerbach, OIA 49-270S1
Sumary of Findings 0IA found that the undesirable effects of accelerating implementation of the Resident Inspection Program would include:
1.
altering the implementation schedule developed by IE which coor-dinates the recruitment, training, and placement of resident inspectors at reactor sites by the end of FY 1981 with a minimum of impact on the region-based inspection program; 2.
a reduction in the scope and quality of the inspection effort perfomed by both region-based and resident inspectors due to junior-level inspectors perfonning increasing amounts of the inspection program; 3.
a reduction in the capability of IE to perfonn reactive inspections in response to major incidents due to inspection resources being spread thinly over all reactor sites; 4.
a dilution of the supervisory and management functions relative to resident and region-based inspectors; and the imposition of training requirements on inspectors which may be 5.
in excess of IE's training capabilities.
Conclusion The report concludes that a more rapid implementation of the Resident Inspection Program is undesirable and that the present scheduled implementation We believe that NRC can accelerate imple-program may be over-ambitious.
mentation only with great difficulty and at the cost of reducing the We also scope and quality of the inspection effort now being perfonned.
believe this will cause a reduction in confidence of regional management that reactor facilities are being constructed and operated in accordance Even if no personnel ceilings are imposed upon with NRC requirements.
IE. we believe there are limitations and constraints which will inhibit IE s ability to station qualified inspectors at all reactor sites sooner than is now planned.
Recommendation _
The report recomends that NRC weigh the potential adverse consequences of an accelerated implementation of the Resident Inspection Program against the value of having an NRC resident inspector at each reactor site at an earlier date than now scheduled.
The principal benefit of an accelerated implementation would appear to be the public perception of enhanced safety of nuclear facilities. The major detriments would be an almost certain reduction in the amount of inspection effort at all reactor facilities, the inhibited response capability of IE, the super-visory burden placed on regional management, the limited training capacity, and the various administrative problems associated with relocating large numbers of inspectors in a short time frame.
~.
l Agency Coments_
' The EDO commented that "IE has reviewed the report and we have no coments on the substance."
j Attachmer t:
Subject fleport cc:
L. Gossick-j'
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N TABLE OF CONTENTS Pg g 1
INTRODUCTION l
SC'JPE OF RF',.'IEW 1
BACKGROUND 2
FINDINGS 1
~
3 CURRENT IMPLEMENTATION SCHEDULE 6
SCOPE AND QUALITY OF REVISED INSPECTION PROGRAM 7
i RESPONSE CAPABILITY OF IE 8
SUPERVISORY CAP /BILITY 0F REGIONAL MANAGEMENT 9
INSPECTOR TRAINING 9
CONCLUSION 9
RECOMMENDATION 9
AGENCY COMMENTS 1
APPENDIX I - Glossary APPENDIX II - Memo to Jim Cummings, Director, OIA, from Lee V. Gossick, EDO, subject " Draft Report on the Undesirable Effects of Accblerating the Implementation of NRC's Resident Inspection Program" O
b
INTRODUCTION _
In March 1979, OIA began a self-initiated revievi of the Nuclear Regulatory Our Connlission's _(NRC) Resident Inspection Program for reactor sites.
intent was to review the early implementation of placing resident inspectors at reactor sites, determine what the resident program was designed to accomplish, and evaluate problems encountered by the Office of Inspection and Enforcement (IE) during initial implementation.
After the start of our review, the incident at Three Mile Island (TMI) occurred, resulting in increased public and political pressure to assign resident inspectors In response at all operating and test and startup reactor facilities.
to this initiative, 0IA shifted its review to provide the Commission with an independent assessment of the problems and issues which might occur if an accelerated implementation of the Resident Inspection Program at reactor facilities is undertaken.
Future OIA reviews will examine in more detail other areas of the Resident Inspection Program.
SCOPE OF REVIEW _
Our review was conducted during the period March through.May 1979 at NRC Discussions were held with Headquarters and Regions I, II, III, and IV.
Regional Directors, Branch and Section Chiefs, regional inspectors, and We other IE officials concerning the Resident Inspection Program.
visited six resident reactor inspectors (three operations and three construction) to discuss the implementation of the Resident Inspection We also reviewed pertinent documents, studies, and computer Program.
data concerning the resident program.
BACKGROUND In 1974, the then Atomic Energy Commission (AEC) initiated a trial program to study the feasibility of assigning inspectors to locations at (or near) reactor sites.
In evaluating the results of the two-year program, IE concluded that the placing of resident inspectors at reactor sitt.s was viable, specifically because it made efficient and effective In June 1977, a Revised Inspection Program use r T the inspectors' time.
(RIP), which included the stationing of resident inspectors at all operating reactors and at selected reactors under construction, was approved by the Commission.
The following chart shows the other aspects of the RIP, which include the formation of a Performance Appraisal Team (PAT) to evaluate licensee and inspector performance and an enhanced career development program:
REVISED INSPECTION PROGRAM _
Revised
~
Inspection j
Program i
i i
i Resident Region Based' Performance
- Career Inspection Inspection Appraisal Development Program Program Program Program
- Performance Appraisal Program is still in the formative stage, and no review of the Resident Inspection Program has been made.
In developing the Resident Inspection Program, IE retained, essentially intact, the region-based reactor inspection program (which was developed and improved over many years).
This program is documented in the IE Manual by several hundred "B" level inspection modules.
In most of the IE regions, certain inspection modules were assigned to be performed by project (principal) inspectors.
These inspectors, generally senior-level people, were assigned responsibility for two or more reactor sites.
In addition to performing inspections, they were also responsible for planning, scheduling, and coordinating inspections performed by ragion-based specialist inspectors.
The specialist inspectors, with detailed knowledge in various technical disciplines', performed the bulk of the "B" level inspection modules.
Also in developing the resident program, IE incorporated additional inspection modules, termed "C" level modules.
It was initially anticipated that the amount of inspection time provided by the resident inspector would allow him to perform all of the "C" level inspection modules.
However, regional management has the discretionary authority to allow perfonnance of any "B" or "C" level modules by resident or region-based inspectors as is considered necessary to accomplish the'inspectio.n program.
IE started implementation of the Resident Inspection Program in Fiscal Year (FY) 1978 by assigning resident inspectors to 20 reactor sites.
The following Table shows a breakdown, by region, of the number of resident inspectors at December ~31, 1978:
TABLE I RESIDENT INSPECTORS AT REACTORS (BY REGION)_
Region Operations or Testing Phase _
Construction Total I
4 1
5 II 5
1 6
III 3
1 4
IV 1
1 2
V 2
1 3
15 5
20 FINDINGS 01A found that the undesirable effects of accelerating implementation of the Resident Inspection Program would include:
1.
altering the implementation schedule developed by IE which coor-dinates the recruitment, training, and placement of resident inspectors at reactor sites by the end of FY 1981 with a minimum of impact on the region-based inspection program;
1.
2.
a reduction in the scope and quality of the inspection effort.
perfonned by both region-based and resident inspectors due to junior-level inspectors performing increasing amounts of the inspection program; a reduction in the capability of IE to perform reactive 3.
inspections in response to major incidents due to inspection resources being spread thinly over all reactor sites; a dilution of the supervisory and management functions relative to
~
4.
resident and region-based inspectors; and the imposition of training requirements on inspectors which may be 5.
in excess of IE's training capabilities.
CURRENT IMPLEMENTATION SCHEDULE _
IE has developed, and is implementing, a phased schedule of placing resident inspectors at all operating reactors and selected construction This schedule of implementation was designed to coordinate the sites.
recruitment, training, and placing of resident inspectors at reactor sites with a minimum of impact on t h region-based inspection effort.
The current manning schedule being used by IE is shown in the following table:
TABLE II RESIDENT INSPECTION PROGRAM IMPLEMENTATION FY 78_ FY 79_ FY 80_ FY 81* FY 82 22**
49 76 93 98 Resident Inspectors
- full implementation achieved (all operating reactors and selected construction sites).
- includes fuel facility resident inspectors.
In implementing the resident program, IE management devised guidance and In a memorandum criteria for the selection of resident inspectors.
dated February 13, 1979, the Acting Director, IE, formally indicated what guidance and criteria would be used for the selection of resident The criteria indicate that the selectee must be at least a inspectors.
GS-13 (GS-12's may be considered under exceptional circumstances), with at least 18 months NRC experience and must meet the training / qualifications requirements in IE Manual Chapter (MC) 0226.
Other specific criteria l
concern the-inspector's professional experience, professional maturity, promotion potential, performance appraisals, and extent of experience as Experience as a project inspector is a project inspector within IE.
important because when an inspector becomes a resident, the project function transfers with him to the site.
l Based on our review, 01A believes that if the selection criteria are followed, a speed up in placing resident inspectors at reactor sites If would not be feasible due to the shortage of experienced inspectors.
the more experienced inspectors (those "th extensive regulatory and nuclear power plant backgrounds) are sent from the regional office, the only people left to perform the region-based inspection program will be newer, less experienced inspectors.
The recruitment of new inspectors is based on an 18 to 24 month training period before they are considered for_ assignment as resident inspectors.
This is partially due to the lesser experience (nuclear related) level of the newer inspectors being recruited. A rush to put resident inspectors at reactor sites would mean that, in some cases, a new inspector would be assigned to a reactor site before IE regional management considers him fully qualified.
The following information details the regional resources available and the number of reactor facilities that would be involved if a rapid Table III shows, by implementation of the resident program occurs.
region, the number of project and specialist operations inspectors and their grades as of April 30, 1979.
Table IV shows, by region, the number of operating and test and startup reactors as of April 30, 1979.
TABLE III REGIONAL OPERATIONS INSPECTORS BY GRADE Project Inspectors _
Specialist Inspectors GS-14 13 12 11 Other GS-14 13 12 11 Other Region I 6
4 2
1 8
6 3
Region II 12 1
4 1
6 4
7 3
1 1
6 5
1 1
Region III 10 4
Region IV*
4 1
2 1
Region V*
5 1
3 2
- Regions IV and V project inspectors perfom the specialist inspections.
TABLE IV_
OPERATING AND TEST AND STARTUP REACTORS Number of Operatinq Number of Test _
Reactor Sites
- and Startup**
Total Region I 16 3
19 Region II 11 4
15 Region III 13 2
15 4
3 7
Region IV 2
5 Region V 3
- statistics taken from NUREG '0020 (Gray Book) dated April 1979.
- statistics per regional officials.
. 9 Correlating this data, Table V shows the number of qualified inspectors, by region, and the number of reactor sites to be covered in a rapidly accelerated resident program, projected by OIA to December 1979 if all operating and test and startup facilities are manned.
TABLE V_
RESIDENT INSPEC_ TORS VS. REACTOR SITES _
I Qualified Inspectors *I Reactor Sites _
Difference _
Region I 10 19 (9)
(2)
Region II 13 15 Region III 14 15 (1)
Region IV 5
7 (2)
Region V 6
5 1
- per IE selection criteria for resident inspectors.
I otal number of qualified inspectors may be slightly or.rstated because t
OIA has not considered NRC experience, promotion potential, etc., in compiling these figures.
The above table shows that if rapid implementation of the resident program occurs, a shortfall in the number of qualified people will exist. This would necessitatt
- ither specialist inspectors or GS-12 project inspect 1rs to be assigned as resident inspectors.
t The short-term effect of placing GS-14 and GS-13 level inspectors at resident' sites will cause the experience level of the regions to be This would leave GS-12 and lower level inspectors severely depleted.
(newer recruits) to perform a large part of the region-based inspection effort ("B" level inspection program).
Regional management officials indicated that allo, wing less experienced pecple to perform the regional support inspections would be an unacceptable situation and that the amount of inspection effort and quality of inspection would decline significantly.
Another factor built into IE's current implementation plan concerns the rotation of resident inspectors.
IE intends to rotate resident inspectors between reactor sites at three to four year intervals.
The current phased implementation schedule allows for rotation of groups of resident inspectors based on when their three to four year inspection tour is This allows for an orderly rotatio with only about 25 percent of over.
the inspectors being rotated at one time.
If implementation of the resident program is increased, with a large number of resident' inspectors being sent out in any one year, this will result in the rotation of a very large number of inspectors in some future year, which would be undesirable and difficult to manage well.
SC0pE-AND QUALITY OF REVISED' INSPECTION PROGRAM
~ Based on discussions with regional officials, we belici
- ~^ 'he "C" level-inspection modules' require-too much time for the retio
, inspector to perform them at the prescribed frequencies and that the combination of the "B" and "C" level inspection programs is beyond the present capabilities of the regions because sufficient qualified and experienced personnel are not available.
Regional officials indicated.that, even prior to TMI, the work load of the. resident and region-based inspection i
programs was too much for the available inspector resources.
One regional official believes the "C" level program is 150 percent of what the resident inspector.can reasonably-accomplish.
In response to the increased work load, one region has modified the "B" and "C" level inspection programs by altering the frequency or extent to which inspection modules are performed.
Performance of the "B" and "C" level inspection programs has been affected by:
(1) the " front loading" of the resident program with senior-level project inspectors; (2) the movement of senior specialist inspectors into project inspector positions in r paration for future assignment as resident inspectors; and (3) the ;iability to bring new inspectors into the " pipeline" early enough to 3ct,uir'e the necessary training and experi-OIA has also ence to be proficient specia~i... or project inspectors.
noted that the inspection efficiency of the senior specialist inspectors has been adversely impacted with the added duties of assisting in the training and guidance of new inspectors.
Regional officials have informed us that their level of confidence in the safety of the react'or facilities they inspect has been based on the performance of the "B" level inspection program and the " quality" of-the project and specialist inspectors.
The regional officials believe the real benefit of the IE inspection program lies in the competence and experience of the inspection staff performing the inspection modules rather than in the written inspection modules themselves.
These officials indicate any substantial reduction in the ability to perform the "B" level inspection program and the " quality" of the resident and the i
regionally-based inspection staff would lessen their confidence in the safety of the reactor facilities inspected.
There is no objective criteria for determining the effects of a reduction in the scope and quality of the inspection program, which might occur by IE has had no the too rapid impicmentation of the resident program.
- previous experience in which the documented inspection program was not performed, so the effects of nonperformance are not known.
OIA was concerned with the seriousness with which regional officials view the prospects of any reduction in the scope and quality of the reactor inspection program as previously performed.
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RESPONSE CAPABILITY OF IE_
l Traditionally, IE has performed both their routine inspection program and also a reactive _ inspection program. The reactive inspection program OIA believes that is performed in response to incidents or allegations.
a' rapid implementation of the Resident Inspection Program will severely limit the amount of reactive effort available to respond to incidents and allegations.
In visits to the regional offices, 0IA observed the impact that response to the incident at TMI has had on the performance of the routine inspection In the four regions visited, all were adversely affected to a Between supplying program.
significant degree in having to respond to the incident.
manpower to the TMI site and other Babcock and Wilcox facilities and performing special inspections at'the other reactor facilities (as a result of TMI), the routine inspection program has been either suspended Estimated regional performance of the routine or severely set back.
inspection program was anywhere from 30 percent behind to being at an absolute standstill.
Region I (where TMI is located) has been most severely impacted in performing routine inspections at other reactor sites, with indications that a continuing strain will be put on the inspection program for approximately one to tvo years due to events at In fact, Region I had to use a resident inspector (pulled from the TMI.
site) to respond to a recent incident at one of their other plants.
Another region indicated that by providing support for the TMI incident, their routine inspection program was at a standstill, and the inspections of a refueling outage had to be cancelled. Most regions ccamented that performing special inspections, responding to bulletins, etc., has necessitated the suspension of the routine inspection program.
To a large degree, two factors are responsible for this situation:
(1) the manning of Babcock and Wilcox operating plants to cover three shifts; and (2) the support necessary to man the regional office response centers 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
The latter is considered to use up four addi-tional man-weeks of effort each week in each region.
A very rapid implementation of the resident program would likely deplete or eliminate the ability of a region to respond to major incidents in the next two or three years, except at the expense of the resident The type of personnel needed to respond to, and manage, program.
incidents are the more experienced senior inspectors who have been assigned to resident sites and will not be available in the regions unless and until they are returned to the regions at the completion of their resident tours.
The totally region-based program had a built-in quick response capability in the form of numbers of very experienced senior project inspectors.
Rapid implementation of the resident program would not provide staffing of the regional offices with a complement of such senior inspectors.
SUPERVISORY CAPABILITY OF REGIONAL MANAGEf;EliT OIA observed that, to date, a regional Section Chief has supervisory responsibility for one to three resident inspectors in addition to region-based project inspectors.
These Section Chiefs have indicated to 0IA that it takes a considerable amount of their time, two to four hours per day, to adequately deal with the resident inspectors and their problems, which is done largely by telephone.
If implementation of the resident program is accelerated, the number of resident inspectors a Section Chief would have supervisory re;ponsibility for would increase significantly (five to eight resident inspectors).
We believe this may be too large a number of new resident inspectors to deal with (especially o
at a long-distance relationship) without some assistance.
When the more experienced regional inspectors are sent to resident sites, the less experienced inspectors remaining in the regional offices require more supervision than the more experienced inspectors dispatched as residents.
However, because the Section Chiefs are spending so much of their time dealing with the resident inspectors, they do not have enough time to adequately supervise the inspectors remaining in the.
The Section Chiefs believe they now spend more time on adminis-office.
trative matters than before the Resident Inspection Program started.
One Section Chief said he now felt more like an administrator than a Other Section Chiefs indicated that they would not be able supervisor.
to provide appropriate supervision if mostly inexperienced inspectors were left to perform the regionally-based inspection effort.
OIA believes that a Section Chief probably cannot effectively supervise more than three to five resident inspectors.
This would mean that as the number of resident inspectors increases, the number of Section Chief positions needed to supervise the residents should proportionately increase. Also,. if the highly-qualified inspaw s are promoted to Section Chief positions, they are lost as a resource for being resident In the short term, assuming accelerated implementation, the inspectors.
program will need these resources at the inspector level.
To help in the conversion to the Resident Inspection Program, some regions have informally assigned, on a trial basis, project inspectors as " resident inspector coordinators" to assist Section Chiefs and relieve them of some of the time consuming tasks associated with the A coordinator for each two to four resident Resident Inspection Program.
inspectors is thought by some regional officials to be an alternative to the proliferation of Section Chief positions.
The " coordinator" is usually a regionally-based project inspector who acts as a liaison between the region and the resident inspector.
The "coordinatsr" usually has daily contact with the resident, helps plan and coordinate regional inspections at the site, reviews and proofs inspection reports, and helps out with other administrative duties for the resident inspector.
It appears that the need for additional Section Chiefs and/or " resident coordinator" positions will inhibit a more rapid implementation of the Resident Inspection Program for at least two years after such positions are authorized and suitable numbers enter the pipeline.
t INSPECTOR TRAINING OIA was informed by the Chief of IE's Career Management Branch, which is 1
responsible.for inspector training, that IE does not have the capacity or present capability to provide the necessary training entailed with accelerated implementation of the resident program.
In light of TMI, IE believes more extensive training should be provided to resident inspectors than'has previously been prescribed. We were informed that NRC has not been able to recruit qualified instructors to fill existing vacancies on the instructional staff and that only limited commercial training facili-ties are available outside NRC.
It appears that a lack of training
~~
resou.rces would also be an inhibiting influence on NRC's ability to deploy fully qualified resident inspectors on an accelerated basis.
CONCLUSION OIA believes a more rapid implementation of the Resident Inspection Program is undesirable and that the present scheduled implementation program may be over-ambitious.
We believe that NRC can accelerate implementation only with great difficulty and at the cost of reducing We the scope and quality of the inspection effort now being performed.
also believe this will cause a reduction in confidence of regional manageinent that reactor facilities are being constructed and operated in accordance with NRC requirements.
Even if no personnel ceilings are imposed upon IE, we believe there are limitations and constraints which will inhibit IE's ability to station qualified inspectors at all reactor sites sooner than is now planned.
REC 0ffiENDATION_
We recommend that NRC weigh the potential adverse consequences of an accelerated implementation of the Resident Inspection Program against the value of having an NRC resident inspector at each reactor site at an earlier date than now scheduled. The principal benefit of an accelerated implementation would appear to be the public perception of enhanced safety of nuclear facilities.
The major detriments would be an almost certain reduction in the amount of inspection effort at all reactor facilities, the inhibited response capability of IE, the supervisory burden placed on regional management, the limited training capacity, and the various administrative problems associated with relocating large numbers of inspectors in a short time frame.
AGENCY C0t@ TENTS The EDO comented that "IE has reviewed the report and we have no comments on the substance" (see APPENDIX II).
s GLOSSARY "B" Level Inspection Program - consists of several hundred separate inspection procedures performed at retctors in both operation and construction.
The program is conducted primarily by region-based inspectors and covers reactor engineering and operations, health physics, safeguards, and other areas. This was the predominant inspection program prior to the placing of resident inspectors at reactor sites.
"C" Level Inspection Program - designed for performance by the resident inspector. The program, an offshoot of the "B" level inspection program, emphasizes direct observation of work activities at the reactor facility.
Functional areas covered by the "C" level program are similar to those covered in the "B" level program.
Module - an inspection procedure in the IE Manual.
The procedures provide guidance to the inspector by indicating what areas, safety systems, or equipment should be examined.
Modules vary in size from one to several pages of detailed inspection steps.
Project Inspecto_r - assigned the overall responsibility for the conduct of the applicable inspection program (construction or operations).
The project inspector is usually assigned one or more reactors and plans, coordinates, and helps perform inspections while acting as the primary NRC contact for the licensee.
He is required to have a general knowledge of the reactor facility and the utility's operations.
Specialist Inspector _ - has a proficiency in one or more specialized The specialist plans and performs in-depth inspections of desig-areas.
nated specialty areas at the applicable reactor sites in the region.
Region-Based Inspection Program - the traditional AEC/NRC inspection program performed by project and specialist inspectors.
Project inspectors are assigned to reactor facilities not having resident inspectors, and specialist inspectors perform in-depth support inspections at all reactor locations within the region.
s 9
s APPENDIX I