ML20035C726
| ML20035C726 | |
| Person / Time | |
|---|---|
| Issue date: | 04/05/1993 |
| From: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9304090037 | |
| Download: ML20035C726 (6) | |
Text
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a APR 5 993 1
q MEMORANDUM FOR:
Edward G. Greenman, Director, Division of Reactor Projects FROM:
Cynthia D. Pederson, Chief, Reactor Support Programs Branch i
SUBJECT:
REVIEW 0F A. T. GODY'S MEMORANDUM ON PROPOSED REVISION TO THE CORE INSPECTION PROGRAM - Alls ITEM NO. 166 Per your request, this memorandum and its attachment provide comments on the i
March 2 memorandum from A. T. Gody titled " Proposed Revision to _the Core
.i Inspection Program." We appreciate the opportunity to comment on this i
memorandum.
The proposed revision to the core inspection program poses additional challenges to our divisions. Besides the need to use budgeted core inspection hours effectively and_ efficiently, we must also strive for consistency in the interpretations of the requirements, regulatory guidance and inspection guidance. The need for good formal and informal communications between DRP -
and RSPB staffs will become more important. The residents should be encouraged a contact the cognizant RSPB inspector or section chief with.
questions on the requirements and guidance, as well as when issues arise.
i Since implementation of the revised core inspection program should result in more DRP inspection reports including emergency preparedness (EP),
radiological controls (RC) and safeguards (SG) inspection activities, it will remain important that a copy of all such reports be sent to the appropriate j
section chief for concurrence so that RSPB can remain well aware of the residents' EP, RC and SG inspection activities and can adjust inspection agendas accordingly.
The memorandum indicates that adjustments should be made to the core program for those sites where an exception to H+1 has been granted. Adjustments may-also be appropriate for any site that does not have an "N+1 resident" inplace at the effective date of the revised core inspection program.
Mr. Gody's memorandum indicated that comments would also be accepted on core procedures which were not being revised at this time.
Our comments include several regarding budgeted core hours for the inspection of biennial EP exercises.
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.i Edward G. Greenman.
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512 We will be happy to meet with you or members of-your staff to discuss:these and the additional comments in the attachment.
" Original signed by Cynthia D. Pederson" f
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Cynthia D. Pederson, Chief Reactor Support Programs Branch l
Attachment:
As stated cc w/ attachment H. Miller, Region III C. Norelius, Region III R. Erickson, EPB/NRR P. McKee, PSGB/NRR L. Cunningham, PRPB/NRR I
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ATTACHMENT COMMFNTS ON MEMORANDUM ON REVISED CORE PROGRAM-I.
Page 2 of the memorandum indicated that IP 93702, " Prompt Onsite Response to Events at Operating Power Reactors," will be removed from the core and placed in the regional initiative and reactive inspection section. The memorandum also indicated that IP 93702 will-be applicable to initial response and follow-up inspection activities by region-based and resident inspectors. Our previously submitted comments on draft IP 93702 indicated that region-based and resident inspectors have roles in determining whether a licensee's response to a reportable event, which the licensee classified as one of the four emergency classes, was in accordance with the relevant EP regulatory requirements and approved emergency plan and related implementing procedures.
Region III EP inspectors have performed evaluations of the EP aspects of every emergency plan activation at their assigned facilities for over five years.
In recent years, this inspection effort has been documented in EP inspection reports and time charged to core IP 82701. Unless the drafts of core IP 82701 and IP 82XXX are revised to require evaluations of the EP aspects of every emergency declaration, region-based and resident inspectors should charge such inspection efforts to IP 93702.
Training to DRP staff on the associated inspection techniques will be provided, as requested.
2.
An event reported per 10 CFR 50.72 (a) or (b) may also have RC and/or SG aspects.
Followup inspection activities on these aspects of reportable events, whether performed by region-based or resident inspectors, should similarly be charged to IP 93702, rather than to the revised RC or SG core inspection modules.
3.
Page 2 of the memorandum listed five matters on which comments were requested. The following comments relate to some of these matters.
a.
Topic No. I addressed the suitability of having residents perform aspects of the core EP, RC and SG core inspection programs. A number of issues must be addressed at the regional level'in order 1
to maintain credible and consistent EP, RC and SG inspection programs.
The residents' suitability will depend, in part, on the quality of their training in the EP, RC and SG functional areas. Once comments on the revised core IPs have been resolved, resident inspectors must be adequately trained. We understand that DRSS/NRR expects some training to be conducted during a resident seminar; however, the duration and depth of this training appears very uncertain. So far, estimates ranging from one to four hours have been mentioned for EP inspection training, with the apparent trend being towards the former value. The proposed training will apparently be given by a combination of regional and headquarters staffs. NRR has proposed that the regional specialist should conduct additional training at each of the sites.
Given these uncertainties and the time constraints before the anticipated effective date of the revised core program, DRP should.
provide DRSS with some indications of the types of EP, RC and SG training needed. For example, should the training be limited to i
the new IPs, or should the training also include background t
information on the IPs' bases in the CFR and regulatory guidance?
More thorough initial training may reduce the amount of effort expended by regional DRP and DRSS staffs in addressing issues that may later be determined as having little or no regulatory significance. Consideration should also be given to the feasibility of region-based and resident inspectors jointly performing their revised core IPs as further training. Due to dwindling DRSS resources, this effort may require extensive coordination, including sending some residents to other sites for inspection / training.
Effective formal and informal communications between DRP and DRSS will become more important following implementation of the revised core program. The goal is consistency when judging the quality of the licensees' EP, RC and SG programs with respect to the health and safety of onsite personnel and the public, as well as the SALP ratings. As an example of formal communications, DRP and DRSS management should continue and strengthen its communications such as obtaining RSPB concurrence on DRP inspection reports containing r
issues in the EP,.RC and SG functional areas.
i Regional DRP and DRSS management should develop criteria for requesting onsite inspection support from region-based specialists. Such criteria should be based on current licensee performance rather than the latest SALP rating for EP, RC or SG, which may not be discernible due to the proposed consolidated
" support programs" section of the revised SALP program.
b.
The resident inspection procedures of EP, RC and SG should remain separate for sub-area tracking. They can easily be summed for SALP purposes.
It is important to track progress of each program area.
c.
Topic No. 4 indicated that the inspection frequency-would be on an annual basis rather than on a SALP cycle basis. This revision is reasonable, assuming the typical SALP cycle is about 18 months.
liowever, DRSS intends to perform IP 82701."Dperational Status of the Emergency Preparedness Program" once every two years, doubling the inspection hours during the program review. This will allow DRSS to observe the off year exercise as part of our program review and utilize our inspection staff and travel funds more efficiently.
d.
Topic No. 5 indicated that adjustments should be made to the core program for those sites where an exemption to N+1 has been 2
t granted. Adjustments should also be made for any sites where a
- N+1 resident" is not inplace when the revised core program -
becomes effective.
The memorandum also indicated that comments would be accepted on those 4.
EP, RC and SG core IPs which were not being revised at this time. The following comment relates to the EP functional area.
Draft IP 82XXX indicated that a resident inspector would only evaluate a
" utility-only" exercise, which does not involve the required participation of state or local government, as a " regional initiative".
Region-based and resident inspectors would, however, evaluate the biennial exercise, which requires some level (s) of state and county participation.
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10 CFR 50, Appendix E Paragraph IV.F.5 includes the term " exercise weakness" and indicates that any weakness shall be corrected.
Region III SALP Boards have correctly recognized the importance of exercise weaknesses by viewing'them as violations of NRC requirements, if the exercise scenario were real.
Regardless of a licensee's current SALP Category in the EP functional area, management should consider having i
resident or region-based inspectors evaluate licensee performance during a " utility-only" exercise, at least with respect to any exercise weaknesses identified during the previous year's biennial exercise.
Otherwise, corrective actions on these concerns may remain unevaluated until the next biennial exercise, which may not occur for another 24 1
months. Although DRSS intends to observe the " utility-only" exercises as part of our program reviews, inspection module 82XXX should also include provisions to perform inspections of " utility-only" exercises.
i In contrast, FEMA's analogous term for unacceptable exercise performance l
by state or county responders is a " deficiency". FEMA requires corrective actions on " deficiencies" to be demonstrated within about
'i four months of FEMA's exit interview following a biennial exercise.-
- 5. to A. T. Gody's memorandum contains several points regarding l
IP 82301 and IP 8?.302 which should be clarified. Although the revised l
core program included evaluation of only the biennial EP exercise, the i
allocated resources are expressed on a "per site per year" basis rather than on a "per site per 2 years" basis. The associated total inspection hours for IP 82301 and 82302 are 54 and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per site per 2 years, i
respectively. Although the biennial exercises are to be evaluated by both region-based and resident inspectors, the " participation" section of the module incorrectly indicated that these inspections will be done "100 percent" by region-based inspectors.
l 6.
During 1992, Region III EP staff and their counterparts in other regions advised EPB/NRR counterparts that the 54 core hours budgeted for l
exercise inspections should almost be doubled, based on the numbers of f
NRC evaluators needed to adequately cover the following response facilities and activities: control room, TSC, OSC, EOF, inplant repair l
teams and offsite survey teams. The performances of licensees' offsite
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L survey teams and joint public information center (JPIC) staff are too often unobserved due to the lack of inspection resources even' though it i
is required by the core inspection module.
If proposed rulemaking to delete the " utility-only" exercise becomes final, Region III management should urge DRSS/NRR to allocate sufficient core IP 82301 inspection hours to allow biennial exercise evaluation groups to be adequately sized to observe all _ response facilities and -
activities demonstrated by the licensees, including the licensees' offsite survey teams and JPIC staff. A revised core inspection budget for a licensee's biennial exercise should be roughly 100 to 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> which should accommodate a six person inspection team for a three day inspection.
7.
We suggest that the new core program be implemented at the beginning of FY 94 at the earliest. Budgeting is based on fiscal year basis and program implementation should also.
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