ML20041E598

NRC Inspection Alternatives.A Study Report

ML20041E598
Person / Time
Issue date:	02/28/1978
From:	Cnver S, Ledoux J, Legasey E, Rehfuss C NRC/IE
To:
References
NUREG-0425, NUREG-425, PB-277-478, NUDOCS 8203110129
Download: ML20041E598 (64)

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BIBLIOGIT AP1"C [ ATA CHEET NUREG - 0425 4 TITLE lJeD SUettiL. ' Add v aluen. No. o. worcornonr) 2 at-eveereas a J s c vf NRC Inspection Alterna61ves S. D AT E HEPORT COVPLE TED

1. AV THORISI 5tephen K. Conver, John C. LeDoux, E<1dard E. Leg:sey and April j,1977 E.,

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Chris Rehfess 9 PE ftF 051 MING ORGANI.' 4160N N AME AND M Alt tNG ADORE S I a tw* J o Cuar#

DATE HEPORY 113UED

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Office of liispection & Enforcement Washington, D.C.

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12. SPONSOHING Of1GAN'ZA TON N AME AND F.AI.ING ADORE 3 Itactede I.o Cwf U.S. Nuclear Pegulatory Comissicq Of fice of Inspection 3 Enforcement 11 CoNTR ACT NO.

Washington, DC 20555 13 TV't OF RE ?0ffI PE RtOO Covt HE D (treci s ve damst Study Report by NRC Staff 14 (ten, are s

15. SUt PLEMEN T arf NOTES

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16. A BU H AC T G(H word. or wul In June,1974, the Office of Inspection and Enforce: ent (IE) initiated a Triel Pror;rsm to evaluate the concept cf assig:;iig inspactors to locations near nuclear power reactors. Tnis two-year program ir.volved tne assignment of two NRC inspectors to locations f rom which tiiey were able to inspect.5 total of *.~our reactor sites.

The e%11uation of this Trial Program concluded that the concept of resident inspectors is vialle because it can provide a number of significant benefits, principally in-volving the efficient an.d ef foctive use of an ins;ector's time.

IE's efforts in pursuing various resident inspection concepts are consistent with the stated interests of the new Administration in improving federai oversight of the This paper describes and evaluates four alternative resident nuclear industry.

inspection concepts vis-a-vis the current progra i, identifies the conc'pt of fuli-time ensite inspectors as a preferred alternative, and describes the tasks necessary to implement this preferred alternative.

17 K E Y WOR DS ANO DOCt.h'f N T AN ALYSIS 17a DESChiPTORS 17n IDE N TIF IE h! opt N E NDE D TE RYS 18 AV AIL ABILITY ST ATF MENT 1? LE CURS TV CLA$$ (7A.s erporri 2 5. N O,C F.' A GE $

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3 NRC INSPECTION ALTERNATIVES A Study Report 1

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S. K. Conver J. C. LeDour E. E. Legasey C. Rehiuss Study Group j

Manuscript Completed: Aprif 1977 2

Date Pubbshed: February 1978 1

Of fice of the Director OfIce of Inspection and Enforcement U. S. Nuclear Hegulatory Commission Washington, D. C. 20555

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Contents i

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INTRODUCTION.,

1 Background.

1 NRC Safety Assurance Program.......

2 The NRC Inspection Prograin....

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Improv ng the Current Program 4

11 DESCRIPTION OF INSPECTION ALTERNATIVES 8

I A l t e rn a t i v e s..................... 8 Components of Alternatives.............. 8 Inspection Alternatives...............

12 i

!!! EVALUATION OF INSPECTION ALTERNATIVES..........

15 I

Introduction....................

15 Evaluation Criteria

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Qu)iitiative Evaluation 17 Quantitative Evaluation 21 1

IV CONCLUSIONS..........

....26 V

IMPLEMENTAIl0N REQUIREMENTS...............

29 Introduction......

.....29 Resource Requi renen ts/Phas ing............

29 i

Irplementation Planning.............

32 APPENDIX A RESOURCE REQUIREMENTS FOR ALTERNATIVE 1-5 APPENDIX B INSPECTOR ONSITE PRESENCE APFLN0lX C PHASED MANF0WER - ALTERNATIVE 3 i

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SECTION I INTRODUCTION _

In June 1974, the Office of Inspection and Enforcement (IE) initiated a Trial Program to evaluate the ccncept of assigning inspectors to locations near nuclear power reactors. This two year program involved the assign-rient of two *iRC inspectors to locations from which they were able to The evaluation of this Trial inspect a total of four reactor sites.

Program concluded that the concept of resident inspectors is viable because it can provide a number of significant benefits, principally involving the efficient and effective use of an inspector's time.

IE's ef forts in pursuing various resident ir-Jection concepts areAdministration in consirtent with the stcted interests of tht This paper tmproving federal oversight of the nuclear industry.

describes and evaluates four alternative resident inspection co l

l inspectors as a preferred alternative, and describes the tahKs necessary to irrplement this preferred alternative.

Background _

The bas's for licensing and regulating nuclear facilities is found in the Atomic Energj Act of 1954, as atended, wn ch established private owner-i The Act also ship and government licensing of nuclear facilities.

prescriced that such facilities are subject te Atomic Energy Comission This (AEC) requirerents to protect the public health and safety.

regulatory autrocity of the AEC was transferred to the fiuclear Regulatory Comission (*.1C) by the Energy Reorganization Att of 1974.

The primary safety consider? tion in the operation of any nuclear facility is the control and containc.ent of radioactive caterial under both norma Since the potential consequences cf significant and accident conditions.

exposure to radiation are large, its risks must te kert as small as j

A number of controls are established for this purpose, possible.

The industry and the fiRC have complementary roles in providing theseThe fiRC cstablishes centrols and in ensuring that they are maintained.

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rules, regulations, standards and guides for tne construction and opera-

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j The licensee has the direct responsibility tion of nuclear facilities.

The to design, construct, test and operate a facility in a safe manner.

NRC, througn its licensing and inspection prcgrans, p-ovides rea!:nable assurance that the licensee is fulfilling this responsibility and that

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the health and safety of the public are protected.

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NRC Safety Assurance Program o

1 An adequate level of nuclear reactor safety is achieved and maintained because plants are properly designed, constructed, operated and main-tained using applicable standards and quality assurance practices.

The NRC standards, licensing and irspection programs assure that these important elenents of safety are appropriately addressed over the lifetire of a reactor. These NRC activities integrate meaningful requirtnents, thorough safety review by botn the licensee and the agency and continuing periodic inspection by both groups. In safety reviews, NRC emphasizes the licensee's systen design for fabrication, construction and quality assurance. In inspection, NRC enphasizes licensee runagecent control of these activities.

The underlying philosophy of the design of facilities and the NRC safety review is defense-in-depth, cr multiple levels of defense against acci-dents. Defense-in depth provides three primary levels of protection.

First, the plan

• is designed to prevent accident. through intrinsic design f eatures, quality components and construction, and redJndant sys-ters and controls. Systens essential to safe control are designed to automatically revert te a 53fC state during adverse Condition 3.

The second level consists of safety systems that protect operators and the public by preventing incidents or mininizing damage should those i

incident > occur. The taird level of safety censists of additional safety sys tens tu accoctedate severe hyputhetical occidents tr.at involve independent failures of the redundant protective systEns at the same time as tne accident they are designed to control. In sunnary, nuclear 'acilities are protected by exacting standards of design and construction, independent safety systens and redundant sdrety syste-c to provide protection in tne unliteiy event of.,uitiple failures. Additional protection is provided by highly treined reactor operators.

The NRC Inspection program Inspections during the licensing process are part of NRC's accep*ance of applications and the issuance of construction cennits and operating l

licenses. Inspections continue thereaf ter througnout tne operisting life of a nuclear fa-ility.

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Priar_to construction, the inspection progra, concentrates cn the applicant's establishment and inplemer.tation of a quality assurance progran. Quality assurance comprises all the syster.atic activities 1

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b that are necessary to provide adequate sonfidence that a key structure, systen or cceponent will perfom satisfactorily in service. Inspections I

cover quality assurance activities related to design, procurement and the plans for fabrication and construction. An acceptable inspection

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finding is a crerequisite for NRC's docketing of an application for

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review and subsequently, for issuing a construction permit.

Durinc construction, a sampling of licensee activities is inspected to j

make sure tnat tne requirements of the construction pemit are followed i

1 and that the plant is built according to design and applicable codes and standards. Construction inspectio"- look for sound management, qualified personnel, quality material, conformance to approved design and for a well foreulated and satisfactorily implenented quality assurance program, j

since these factors are most impo tant to the successful construction of i

a nuclear plant. The licensee's implerertation of there factor $ is assessed by exaraination, on a spot eneck t, asis, of construction activities.

As construction nears completion, preocerational testing to dronstrate the operational readiness of the plant and its staf f begirs. Inspections 1

I during this chase determine whether the licensee has devcloped adequate 1

t?st plans, assure that tests are consistent with SRC recuirer.ents and determine that the plant and its staff are orepared for safe operation, j

Inspections during the preoperational phase involve (1) reviewing overall test ran:gement prccedures; (2) examining selected test procedures for technical adequacy; and (3) witnessing and review of selected tests to detemine their outcomes and the consistency of planned and actual tests.

In addition, inspections review the qualifications of operating person-nel and assure that operating procedures and quality assurance plans are developed.

About six r.onths before NRC's operating license is issued a startup phase begins in preparation for fuel loading and pcwer ascension.

Following the issuance of an operating license, fuel is loaded into the reactor and the actual startup test program begins. As in pre-operational testing, f RC inspection ec;hasis is placed on test management procedures and results. The licensee's startup test i

management systen is examined, test procedures are analyzed, tests 1

are witnessed and licensee evaluations of test results are reviewed.

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When startup testing is corpleted satisfactorily, routine operations l

begin. Thereafter, NRC continues its inspection program throagnout I

the operating life of the plant to verify that the licensee's control l

systems assure the safe operation of the plant in compliance with NRC l

requirements. Specific elements of the cperating relctor inspection program are:

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j Reviews of the basic systems and procedares the licensee I

follo s w be certain they conforn with requirerents, are technically sound and are implerented properly.

Analysis of records of licensee operation and interviews of personnel to confirn that actions called for by the prescrited systems and precedures are routinely followed, s

Periodic verification of licensee and system perforeance j

by reans of independent NRC observations, tests or reasure-rents.

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Additicnal inspection activities are also conducted. Each year inspectors examine licensee Feview and AudTt co c.ittee actions and chances to the qaality assurance prograr. and the operating staf f.

They also examine Licensee Event Peports; facility operating precedures; training program details; refueling activities; scent fuei shiprents; and functional testing, calibraticn and raintenance activities. In addition to these defined ins;ection activities, approxir.ately 20f, of an inspector's on-site tire is schedu17d for ccnducting unpecgramed direct ooservations of the plant or exanining specific areas of interest or concern. liist inspectors also ccnduct detailed inscections and investiqations in specific areis as a rescit of apparent plant weatr.e ses, events or allegaticns.

i in su rary, the i.4C inspection progran is designed to provide reasonable assurar.cc that c blic health and :,afety are protectec :.y.monitcring i

licensee activities througnout a nuclear facility's lifetire. To do tnis, 2

the inspection pro' iran verifies that tre licensee's centrol prograts are ircle ented; that plants are constructed preserly; that required tests i

are conducted and results are acceptable before routine 0;erations begin; and that the plant is operated safely.

j Irpreving the Current Prcgram 1

The current inscection progran has evolved over the past twenty years as the nuclear industry, safety technolcqy and the safety awarenus of the public have grean. The inspection crc :ran reflects the telief that safety carnot be l1spected into a plant. Patter, safety is' the result of conservative design, quality corpor.ents, preper construction and testing, qualified p20ple and sound anage-ent a; plied at each phase.

The pr0per rcle for inspection is to assure that these elaTents are maintained.

In keeping with this philosophy, the !;RC inspection progran concentrates on licensee ccntrol activities. In ersnasizes centrol by licentee r.ana-gerent through quality assurance prcgrars and systems, ratter than '.RC 1

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' acceotance of components and hardware systems. If licensee activities I

are properly Controlled dnd conducted, then the resulting systems should

,I function so tnat the safety afforded by the defense-in-depth design of the facility wi.1 be realized. This philosophy is at least partially i

re!.consible for the excellent safety record of the nucicar industry.

The c.urrent program nomally is conducted by inspectors or teams of inspectors operating from five Regional Offices, perforrning periodic i

irnpections at licensee sites. About 25!, of an inspector's time is J

spent casite inspecting licensee activities while mst of the balance is spent in the regional offices preparing for inspections, evaluating inspectio's findings, anc documenting inspections performed. Since on-site time is limited, there is limited opportunity for cirect observa-1 tion of licensee activities, and the current program snust place l

considerable confidence on the accuracy and completeness of licensee f

stat? rents and documnts that attest to those licensee actions perfcrmed without FRC direct observation. Because of tre reliance placed on these licensee statements and docurents, it wculd be prudent to increase confidence in their accuracy and completere's. By 1

i expanding verification of licensee actions, NRC would have more confidence in licsnsee records and could more readily assess the 4

safety of licensee activitics.

1 This post-performance audit would cnnsist of the h0C or its contractors verifying the accuracy and completeness of the licensee records thrtugh an independent rograal of oirect ;;,)asurement.

In dddition tn this post-perforer.ce verification, rore direct n$ser'/ation of activities underway licensee sites shculd increase TAC confidence that the 11cer.see at control systens produce proper actions.

In addition to providing an ir. dependent assessment of licensee performance, the inspection program today is thought to provide a posi?.ive incentive for proper licensee perforrance. This incentive is apparently based upon inspector presence onsite and licensee uncertainty as to what is to be inspected. The Trial Program evaluation concluded that licensees place greater emphasis on regulatory requirements Js associf tion between fAC inspectors and plint staff is increased. More inspector presence on-site should therefore encourage ir. proved licensee understanding and a.<areness of regulatory requirements.

3 increasing the time an inspector spends onsite provides more opportunity for directly observing licensee activities and assessing the overall j

safety condition of the olant. Because of the irproved familiarity with a specific plant that would result froai rore onsite time, an inspector, in addition to detecting instances of nonco pliance with regulations, would be tietter aisle to assist in idcntifying potential problem areas before they de< eloped into safety hazards. inerefore, increasing onsite time would s esult fi1 a higher level of cc,nfidence

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that licensed activities are conducted safely.

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i The existing tiRC inspection program provides an adequate technical basis t,pon which to assure the safety of licensee operations. The

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improvvents identified atove would strengthen this technical basis and. at the sate time, add an ir.portant benefit by increasirig the J.

peblic perception of the adequacy of tha f4RC inspection program.

1 Regardless of its technical basis, an inspection program that f ails 1

to convince the public of its adequacy will continually be the suwject of controsersy and suspicion.

Criticisms of the eFisting inspection program follow ti'ree Consistent theres: (1) there are too few liRC inspections: (2)inspectorsspend a

too little tire actually at the f.:9t; and (3) even when onsite, inspectors spend too much tire reviewing paperwork as opposed to 1

observing actual work or observing and conducting tests and neasure-nents. A decided reve by ?!RC into note direct verification /reasurements and refinino the orogram to provide note onsite tim enhances the base for f.RC technical judgmnts and, at the sare tine, effectively responds r

to those criticises, These changes are expected to:

4 Increase fGC knowledge of the conditions at a licensed j

faci.ity and provide a better technical base for regu.

latory action.

f I.essen the prograr.'s reliance on the accura:y and ccealeteness of iicensee records by irproving the inspector's ability to independently vert y licensee i

perfor-ance.

Provide additional assurance that licensee ranagenent control systens dre ef fective and tnat licensee rer-forrance is acceptable.

Ir. Drove the fiRC posture relative to incident response.

As an additiont.1 benefit, the Trial Progran suggests that these changes should also irgrove the credibility of the prograr. in the licensee's eyes.

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the NRC inspection program should satisfy:

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k Establish greater f4RC presence onsite at licensee b

facilities.

Ci Increase the direct observation of key licensee h

activities by fiRC inspectors.

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Enhance the confidence in licensee records by increasing f(RC direct verification /neasurettent activity.

The sections that follow idencify and evaluate four alternatives that the Office of Inspection and Enforcement could pursue to acnieve these

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goals.

Each of these alternatives preserves the underlying philosophy of fiRC regulation and inspection. The licensee would continue to be directly responsible for designing, constructing, testing, and operating the facility in a safe manner. f(RC inspectors, whether stationed unsitt or in Pegional Of fices, would remain independent of the licensee's control Systems while assurir.g that the licensee was providing adequate protecticn. Finally, each of the alternatives maintains the present scope of responsibilities of the Office of Inspection and Enforcenent involving the evaluation of licensee p2rfcruance with respect to safety and safeguards c.3tters.

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1 SECTION II t

DESCRIPTIO!l 0F ItiSPECTIO!1 ALTEP..'iATIVES 3

i Altricatives Five alternatives are described that permit varying degrees of inspector presence, direct observation of licensee activities and the use of independent measurements. The Current Progrem, relying upon regional inspectors, is alternative I and is used as a baseline against which the otha. alternatives are compared. The Site Vicinity concept, alternative 2, involves placing some inspectors in the vicinity of clusters of reactor sites and suppler.entino their inspection effort with special perfornance appraisal and direct verification /neasurement teams. Alternative 3. Full Time Onsite, calls for an flRC inspector at every reactor site to provide daily insocction coverage. Alternathes 4 Continuous 01 site, and 5, Continuous in Cortrol Room, provide extended inspection coverage and ruuira an f4RC inspector to be continuously pre-sent at the site or in the control rocn of each reactor with an operating license. Each of the alternatives that olaces an inspector onsite would also involve in-depth perfor-ance appraisal and direct verification /

r.easurement inspections conducted by a skilled and diverse gro p of t;RC inspectors.

Components of the Alternatives j

There are four basic components that corprise the insocction alternatives identified above. To avoic duplication, the coroonents are identified and discussed it a conceptual level before they are combined to form insp2ction alternatives. The insccction components are:

Regional inspecticns involving !iRC inspectors, either project or technical support, operating out of Regional Offices (as in the present prege m).

Resident inspectiens_ conducted by inspectors stationed at (or in the vicinity of) licensed facilities.

Direct verification /measurerent inspections conducted by flRC inspec. ors and possibly centractor personnel to observe work in progress or independently test licensee activities.

Performance appraisal inspections conducted by a select group of skilled and diverse f4RC inspectors to provide a short period of concentrated inspection of any or all aspects of a licensee's operation.

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bsing the regional inspection approach, flRC inspectors are located in Regional Offices and periodically travel to licensed facilities to make In the present program, an inspector sper.ds ebout 25 a

inspections.

percent of total available tirre onsite at licensee facilities, andeach I

of two to three days duration each conth, either by a single inspector i

or by a team composed of several inspectors.

Regional inspectors are of two main types, project and technical support.

Project inspectors are usually generalists with technical knowledge in They are the broad spectrum of activities conducted by the licensee.

resp rsible for conducting inspections in certain areas 6hd for monitoring i

the everall inspection status of a site, coordinating the total ongoing

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inspection effort at the site, assuring all necessary inspection require-nents are fulfilled and following up on all outstanding items and enforce-i i

l Project inspectors normally serve as the point of contact 1

nent actions.

Technical I

between the licensee and the reginnal inspection organization.

t support inspectors are specialists that possess a high degree of expertise in one or nore engineerino or scientific disciplines related to licenste Technical surport insoectors provide coverage of specific activities.

technical areas and suppori, the inspection effort of the project inspectors.

Under the current regional inspection program, inspectors examine technical procedures, nanagement controls arid licensee records and observe licensee activ ties. Approxinately 20-30% of onsite time i

is spent in direct observation and independent neasurenent.

Using the resident inspection _ concept, some inspectors would be located either at or in the vicinity of licensed facilities. Project inspectors would be best suited for resident inspector duty, because the situations i

Technical encountered at the site nay cover a spectrum of activities.

support inspections appear more suited to regional rather than resident J

inspectors because the expertise of the technical specialist is rcre narrow than the project inspector and can be used more effectively and i

a There are ef ficiently when applied to a number of dif ferent locations.If located near " clusters" several possible variations of this approach.

of reactors, one site vicinity inspector might be able to provide inspec-tion coverage to all the clustered iTcITitics by spending a percentage of Assigning ore onsite inspector _ to each facility would his titre at ea:h.

Continuous _

pernit the irupector to concentrate eff orts even further.ons a number of inspectors to each site.

project inspectors, technical support is still provided by inspectors from the Regional Offices.

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The concept of resident inspections was evaluated in the Trial Resident i

Inspecticn Progran. The Trial Progran concluded that the cencept was a j

viable irspection mthod and contributed to the effectiveness and efficiency of Inspectors. In addition to the benefit of increasing licensee wareness of regulatory requirenents cited in Section I, a resident inspector was shown to enhance idRC awareness of facility status. L.icensee acceptance of the flRC inspector was improved which resulted in easier access to ftcility records and increased independ-ence of inspection effort. BecaLSe of the results of the Trial Progra the resident concept is used as part of each alternative j

to the ;urrent program considered.

One of the prime functions of an onsite inspector would be to extend fiRC onsite examination of the implementation of the quality assurance progra11 through increased cirect observation of the work and testing procedures. The ensite inspectors would deternine that licensee work and raintenance procedures woe adequate and, by observatior, vetrify that ti.ese activities were conducted properly and at the requircJ frecuency. In addition, inspectors would exanine events to determine the adequacy of licensee actions and reports. Their proxinity to and familiarity with a specific site would allow inneciate oasite inspector response to significant events. Although cnsite inspectt,rs could not possess all the specific expertise and skill of the regional technical support groups, they would be capable of recognizing actual and potential safety problems and, if necessary, could then refer these itt:ms to the technical support inspectors for resolution, independent Verification has two forms - direct observatien Jf work and confirmatcry reasurer.ents. Both types of independent ver fication are intended to provide credible assurance that the licensee has con-ducted various types of vork properly. Direct observation involves witnessing licensee activities in progress. This "over the shoulder" observation can be done by both project and technical support inspectors.

While the opportunities for direct observaticn are probably greater for resident inspectors, it is comon practice for regional inspe: tors to observe carticularly significant work in progress as cart of the current inspection progran. The nu-ber and tyces of these observatioqs should be based upon a determination of the rost safety-significant licensee work units, the degree to which this work can be meaningfully observed 3

and the degree of confidence desired.

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j Confirmatory reasurements differ from direct cbservation in that they l

g are " hands on" (as cpposed to "over the shoulder") inspections. These I

types of inspections involve technical verification that the licensee j

has done certain work properly. Through confirratory reasurenent in-i specticns, those licensee activities tnat are not subjected to direct observation by the resident inspector or specialists still are subject 0

t3 direct verification by the fiRC but on a post-perforrance basis.

This inspect on technique can increase the fiRC's confidence in the 2

technical perforrance cf the licensee and in the accurat.y and complete-e ness of licensee docu entation. While some measures ray be appropriate for an onsite inspection, it may not be an efficient allocation of 1

re'.ources to duplicate at each site the confirmatory measurenent 5

capability that involves specific technical talents and equipnent.

f Therefore, fiRC inspectcrs supplerented by contractor technical support would be used as specialists to perform these technical reasurements f

and tests. As in the case of direct observation, the nurber and type i

of confirmatory reasurenent inspections would be based upon the degree to which safety-stanificant plant parameters should and can he verified by test or reasurerent and th; desired degree of confiderce.

Perfornance appraisal inspecti).15 am thorouah critical reviews of licensee facilities by a select gro'ap of experienced fiRC inspectors.

P511e the current inspection program appraises the perforrance of

.cnsees, intensive perforrarce appraisal inspections are..ot ennducted a part of it.

These appraisals would provide an additional layer of

.inspection in assuring the safe operation of licensed facilities.

Inspectcrs would be chosen for their expertise and experience. The specific disciplines needed on a particular team wo'Jid te based on the type of facility inspected, the type of problers experienced at that facility in the past and other factors.

Perforrance appraisal inspections would be aimed prirarily at the licensee's total control of plant activities. Therefor 2, the orienta-tion of these inspactions would be toward corporate and offsite management contrcl as de-enstrated by onsite licensee perfor.-ance. The onsite in-spections would involve cetailed exanination of selected areas of the licensce's activities supplenented by a reliance on the direct verifica-tion /reasurerent periorred by the regional or resident and the technical support inspectors. The perforrance appraisal inspections woulo verify that the licensee control systems assure adequate perforrance in safety-related natters.

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The tearas conducting the performance ap;taisal inspections would examine essentially the sare areas of different licensee's activities without regard to regional boundaries. This would bring a national perspective to inspection and allow the fiRC to obtain a rcre objective view of licersee perfomance and of the effectiveness of the total regulatory j

prograrr. In addition to appraising the licensees' activities, t!.a a

resulte of perforrance appraisal inspections should ir.dicate the effectiveness of the rout;ne inspection progran and provide it.Wht into the perfomance of the onsita inspectors.

i The frequency of perfomance: appraisal inspections nipt average on'* per year f er site, with nore frequent inspection devoted to licensees with known or suspect?d problem areas. A desirable output of these appraisal inspectims would be acknowledgment of those areas in which the licensee was doing a particularly good job.

1 The timing of these inspections would be based on factors such as:

(1) the tire since the last appraisal inspection; (2) licensee per-forrance; (3) requests by Regional Offices; and (4) other events warranting examinatico. Tears would establish specific objectives and schedules for each ins;ection and focus on rajor safety-significant The teams would prepare insoection reports with findings that areas.

would be turned over to the Regional Oi' ice for followup or for enforce-rent. These inspections would not replace reactive inspections that the Regions would perfom to respond to incidents or allegations.

Inspection Alternatives The basic co ponents can te ccrbined into inspection program alternatives that increase inspector presence and strengthen the progran's independent verification capability. Using the current inspection progran as a baseline, this section briefly describes four additional alternatives that represent progressively increased )ffort. Evaluations of the base-line current procran and the four other alternatives are presented in Section Ill.

Alternative 1: Current pecarar. The current inspection program relies on regionally-based project anif technical support inspectors. Inspectors ceriodically travel to licensed facilities and each facility typically receives at.out-two inspections per renth of two to three days duration by a single inspector ur a team of several inspectors.

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" l Alternatise 1 is used as the baseline for evaluation. The program described in Section I would grow in succeeding years to accomudate additional facilities and workload but the technical program and 8

inspection approach would renain substantially unchanged.

Altercative 2: Site Vicinity Inspections. This optiren involves locating 1

inspectors neer clusters of reactor sites. The recent Trial Program to evaluate this concept concluded that the concept is preferred over regional inspectors 'or a cluster of three or more operating reactors within a radius of r out 25 niles. The Trial Procram evaluation also indicated J

that the site-vicinity concept appears appropriate for construction sites as well as o;,erating reactors. In alternative 2. a site vicinity inspector is assured to perforn that part of the routine inspection progran norully n pending on performd by project inspectors based in a Regional Office.

e the nutber of reactors and nurter of sites in the cluster and an individual's technical cualifications, some technical support inspection requirenents could also te covered by the site vicinity inspector. In addition, the site vicinity inspector would spend considerable tine onsite observing and evaluating licensee activities. Based upon projections of the nunber of reactor sites in various phases and locations, it is estinated that site vicinity inspectors could be placed at 11 clusters involving 21 sites in FY 81. The site vicinity inspections would be supplenented by perforrance appraisal inspecticns and regional tecnnical support inspec-tions each with increased direct verification /reasurerent capability.

Alternative 3: Full Tire Cnsite Inspections. The third option to accon-plisn the goais set fortn in Section I is to locate at least one fP.C inspector at each power reactor site. For a fully irplerented program, one inspector would be assigned for each reactor ; nase (constructinn, preoperational testing, startup or operations) represented at a site.

If tnere were nore than two reactors in any cne Of the phtses, additional inspectors would be reovired so that no inspector would cover core than two reactors. The onsite inspector would perforn the project portion of the routine inspection program and scre of the technical support portion.

The reraining technical support wou.d be provided by tne Regicns. In addition to conducting the defined inspection progran, the onsite inspector would perforn indecendent inspection, additional direct observation and other evaluation of licensee activities.

The onsite inspector would raintain an office at the reactor site and would perforn the duties described previously. ';ork area inspections would be unannounced to the licensees and would te perforred during non-prire as well as prime shif ts.

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t t Perforrvince appr31 sal and corfirmatory reasurement inspections would

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i also be included in alternative 3.

Alternatiye A: Continous Onsite inspectors (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day 1. A s

fcurth cotton to accor.plish the Section I goals is to locate a sufficient number of inspectors at each site with a reactor in startup For or operation to provide continuous coverage of these facilities.

reactors in construction ant'. pre-operational testing flRC would continue to orovide the full time c.isite coverace described for alterrative 3.

Alternative 4 is similar to alternative 3 in 311 respects, except it l

requires a rareater level of effort due to the continuous coverace in stertup and operation. Perfornance appraisal and confirnstory recsurenent inspection would be included in this alternative.

Alterna!!ve 5: Continuous Control Roon Inspectors (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day).

The finai alternative involves placing a nurber of tJ<C inspectors in each cower reactor con.rol room to provide full-tire coverage. Inspectors nonitoring control room activities on a full-tine basis would be dedi-cated to that task and would not perforn the routine inspection pror; rim or the other duties of regional or resident inspectors. Cecause of :ne iroortance of the other onsite operations such as work and r:aintenance activities and the testing and startup prograns, tne continuous control r00n inspector rust be supplenented by an inspection prograts that exanines the other facets of a licensee's operation. The Regional and site vicinity inspection con:epts are inconsistent with placing an fGC inspector con-tinuously in a control ror';.t.

If an !GC inspector is to observe c ntrol operations to the degree a ronitor would, then, at a mininum, an roca expeaienced generalist snould probe other aspects of licensee operations to t'te sare depth. Alternative 4 is consistent witn the control roon Therefore, concept but would d.:plicate ruch of the control roon effort.

tFe control room nonitor was added to the Full Tire Onsite alternative to raiataia consistency and avoid duolication of wor l:.

Alternative 5 is identica' to alternative 3 with the addition of centrol room inspectors.

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.J SECTIO?4 III i

EVALUATION OF If457~ "0!i ALTERNATIVES Introduction The criteria that constitute the basis for evaluating inspection I

alternatives iniolve both qualitative and quantitative considera-This section defines these criteria and examines the benefits f

tions.

of each alternative as well as the costs. To provide a censistent basis for evaluation, each alternative is assumed to be implemented and operating in a steady state condition by the end of FY 81.

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Evaluation Critaria, The Of fice of Inspection and Enforcement interacts wit i other functional eierents of fGC and with licensees to insure safe licensee operations.

During the licensing process, fiRC verifies that licensees are competent to co" ply with regulatory requirements. Subsequent IE inspections deter-If mine whether they are actually complying with these requirements.

instances of,oncor.pliance are found, IE undertakes the measures neces-Furthemore, IE sary to ins ere that licensees take corerstive action.

identifies potentially unsafe conditions in nuclear facilities that indicate inadequate regalatory requirements, and provides feedback to licensees and appropriate fRC of fices when these situations are found.

The ability of LE to detect r.cacompliance and unsafe conditions depends Therefore, upon the type of inspection program and how it is used.

inspection approacnes and alternatives shoJld be judgad, at least in part, on how they satisfy the following criteria associated with program perfomance:

Inspectors should be thoroughly familiar with Cemetency.

the regulatory program, technically proficient and well acquainted with the facility.

The inspection program should maximize the inspector's Utility.

capabiTity and opportunity to observe those licensee activities that are meaningful to safety.

Fl exibil i ty_.

The program shoulj provide the opportunity for inspectors to pursue noncomplitnce and safety matters to a satisfactory resolution.

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Obiectivity. Tre program should provile for the evaluation of Ticensee activities without significant influence from inter-perscaal relations. Correction of safety-relatec proalems must be achieved without the involvenent of inspectors in i

licensees' internal control system.

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Motivation of Licensees _. The program should reinforce contin-

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1 uing licensee aurenass of and attentior to responsibilities to protect the public. In this regard, the progran should provide licensees with encouragenent to irprove and should ninimize 1

disruptions of licensee activities.

l These qualitative criteria pertain to the ability of the inspection program to detect and achieve correction of instances of noncorpliance and reicoed to other areas of concern. However, the viability of the inspection alternatises also depends upon quantitative " actors describi.,g program benefits and costs. These factors are:

f'.arpower Requirenents. fiu-ber and type of people rquired.

Dollar Costs. "anoower and other program costs expressed in i

HoTTir arounts.

Profray. Effectiveness and Efficien ic..hasures expressed in tert:s of inspe, tor onsite tire. ',. nile inspectce onsite tire is not a direct reasure of effectiveness or efficiency, it can be used as an indicator since the Trial Fesident Inspection Progra-1 concluded that in:reased onsite presence:

Ircroves inspector effectiveness through increased direct observation of facility c.cerations.

Enhances MC awareness of facility status.

Enhances inspecter acceptance by the licensee resulting in easier access to facility records and increased independence of inspecticn effort.

Peduces licensee efforts required to scoport the inspection progran.

Enhances licensee ranacerint attention to 12C requirerents.

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i flualitatise Evaluation This portion of the evaluation considers each of the inspection alternatives in light of the five qualitative criteria: :orpetency, I

utility, flexibility, objectivity, and notivation of licensees.

Alternative 1: Current Progry Competency. Inspettors are highly qualified and coepetent 3iid have excellent kno6cdge of a nu-ber of relevant tech-nical disciplines as t ell as the various facilities they inspect. Forral training opportunities are arple and readily accessible and the Regional environrent perrits extensive interaction with peers. Since inspectors are assigned to rore than one plant, they ray not be totally familiar with the details of each plant. Treir knowledge i

of plant status Cepends on visit schedules and telephone contacts with licensees.

"tility. Because of travel requirerents and other practical constraints, a regicnal inspector is able to spend about 25 percent of total available tire onsite. Further in:reases in onsite tire would routinely require inscectors to traval cne week out of every two. frt opportunities for evaluating all aspects of plant activity are li-ited by the enount of onsite tire available.

Flexibility. The present pronran of regional inspections l

encourages inspectors to pursue compliance and safety-reiated ratters to resnlution. As a practical ratter, however, tne onsite tire available limits the inspectos oDportunity to obtain resoluticn of individual problens and allows less than 10% of the ensita tire in independent inspection effort to pursue natters of technical interest outside tne pre-planned j

program, Objectivity. The opportunity for loss of cajectivity by regional inspection is small.

"otivation of Licensees. As shovn by the Trial Resident Inspection Frogran, Ticensees awareness of regulatory revire-rents can be increased through more frequant intmaction with NRC inspectors. The current progran does not provide ruch opportunity for such interaction, a

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2 Alternative ?: Site Vicinity i

Competency, inspectors would become enore famil.ar with the

. facilities for which they are responsible because Lt.ey would j

typically spend part of nearly every day onsite. However, f

dispersing inspectors into a large nutter of small groups would preclude day-to-day interaction with other inspectors 1

and supervisors that contributes both to professional growth j

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and current knowledge of regulatory requirenents.

Utility. The site vicinity approach would permit inspectors to spend a greater amour.t of tirne onsite than the regional inspection approach and would allow better knowledge of site i

activities. Moreover, inspection effort could be better scheduled to coincide with significant site activities.

Flexibility,. The ability of the site vicinity inspectors to pursue tratters of safety concern would be er. chanced because of the increased onsite tire, f amiliarity with the facility and the opportunity for non-price work nours inspections.

Objectivity. The site vicinity ir.spectors would not maintain an onsite of flCe and would sD?nd only a portion of tirr.e at the site. However, as tne only fiRC ernployee in the vicinity, day-to-day techn1 Cal and professional interactions could be limited to those with licensee employees. While the potential for loss of objectivity would be greater than that of the regional inspector, the Trial Program inspectors suf fered no detectable loss of objectivity.

Motivation of Licensees. Licensee attentiveness to regulato y requirements should be enhanced at those fe.:ilities where site vicinity inspectors are assigned. However, a major drewback of this appruach is that inspectors would be assigned to a limited nerber of sites that would be chosen on ti.e basis of geograp'iical, rather than perforr'ance, considerations. Hence, the positive benefit of tnis motivation would be realized only at tnose sites located in clusters.

Alternative 3: Full Tine Onsite Competency. Using this approach, inspectors would develop consideraole familiarity with the licensee facility, since each inspector's responsibility would be linited to a single site. Without periodic reassignment of inspectors, however, a

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an inspector riight not gain the breadth of eOerience that cones fror: exposure to a nurber of dif ferent facilities.

l'urtherrore, providing formal training to onsite inspectors would pose practical logistics problems. Or. site inspectors t

would also losa the daily professional interaction with NRC peers available to regional inspectors.

Utility. Inspectors would be able to conduct inspections at various tir.es during the daily work cycle, including both prim and non-prirre shif t operations. Ins;ector presence onsite would be significantly increased and coald be telectively applied to erphasize safety-related licensee activities. Inspection activities would be essenti311y unar.nour.ced.

Flexibilg. The increased tire onsite would provide the inspectcr amle opportunity to detect and verify correction of rutters of safety concern.

Objectivity. Because of the daily working relationship between inspector and licensee, this apprcach offers greater

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risk of loss of inspector objectivity tnan the site vicinity approach. A closely related problem is the potential for inspector ir.volverent in the licensee's ir.ternal decision-rekino proctsses. As in the site vicinity alttrnative, the inspector might find. professional and sectal ;eers only anong tne licensee eeployees.

Motiv&tien of Licensees _. This alternative would provide increased inspector presence onsite and stculd have a positive influence on motivation. The activities available for inspection should be sufficient to make full and reaningful use of the inspector's tire.

Alter _ native 4: Contir.uous Onsite_

Alternative. provides inspectors around the e

clock at operating reactor sites. These ir.spectors would

.h Competency _.

becom familiar with a specific facility, but would suffer j

e the sa e professior.al disadvantages identified in alterna-tive 3, with the exception that they could interact daily with a s ull group of NRC peers, i

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l The nurber of inspectors needed to provide continuous coverage of all reactor sites would require a subst:ntial increase in the size of the inspection force. The ability of tiRC to expand the inspector force to this extent, while risintaining nigh standards of quality is questionable. Also, j

retaining high caliber inspectors would be difficult, since rany of them would be assigned relatively unchallenging duties during the non-prime shifts.

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'Jtili ty. The fiRC inspection program errohasizes control by s

Ticensee canagement through quality assurance progra.ns and i

systems. While placing inspectors continuously onsite j

',ould theoretically..axinize the opportunity to detect 1

concoroliance, it would not provide appreciably rore per-spective to the licensee activities than alternative 3, because there is not sufficient licensee activity to fully utilize inspectors on a three shi't basis.

4 Flexibility. Continuous inspector presencr* would provide

reater opportunity for prompt attention to ratters of tech-nical interest.

Objectivity. Tre ocssibility of loss cf c:jectivity is less w'nen a nurt.er of inspe: tors rather than ar. fr.dividual is stationed onsite tecause tne group would provide profes-sional interaction and dissuade overfariliarity with the licensee.

l'otivatien of Licensee 2 Lir2nsee awarer.ess of and attention j

to regulatory recuirerents should be er.har.ced.

Alternative 5: Continuous in Control Poon Competency. The qualifications of control roon inspectors are r.ecessarily different f rom those of current fiRC inspectors.

i!hile control roon inspectcrs would need knowledy of HRC rules and regulations, they would also recuire training and experience equivalent to that of Senior Peactor Cporators to reaningfully ronitor control room activites.

Since control room inspectors would serve a renitoring functicr. and rarely exercise their full orofessional cap-abilities, it would be difficult to raintain technical 1

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h proficiency during the onsite tenure despita supplemental training. In addition, retaining qualified control reon inspectors could prove difficult because of the nature of f

f, the job.

I Only in the event that the licensed operator did Utility.

l not perform in a manner to assure the safe functioning rf the plant would the control room inspector be called upon to act. These instances occur infrequently. Moretver, increased inspector resources could be used more effec-tively if applied across the total plant rather then concentrated in control rocm operations.

Flrxibility. It is not likely that these insrectors viuld centribute significantly tc IE's ability to detect c.d e.chieve correction of noncempliance or unsafe conditions because their activities are limited to one facet r.f licensee operations.

Objectivity. Because of the close and constant working

• elationship betWEEn Control room inspectors and licensed reactor operators, the possibility exists that interpersonal g

relation:, w.'uld entcr into the inspector's evaluation of the j

safety of control room activities. In situations where promp I

and responsible actions on the part of the licensed operator

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are needed, the tendency may exist to cc.nsult with or defer to the NRC control *oom inspector those decisions that must be j

made by responsible licensee managea nt.

Motivati_on of Licensees. The control room inspector would impact only control room personnel and could positively i

influence then to conform (o requirements.

Quantitative Evaluation To provide a consistent basis for evaluation, each alternative is projected to rY 81. Estimates of resource requirements (manpower and dollars) and onsite time are based on currently forecast FY di workload with each inspection alternative operating in steady state.

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Manpower Requirements. Alternative 1, tha currer.t program, relies on regicnally based inspectors to iccomplish the entire inspcction workload. Alternatives 2-5 requin: a mix of regional and onsite inspecto*s complemented by Special Inspection Teams. The manpower requirements describe the relative effort involved in accomplishing

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the alternative inspection prograns and serve as a basis for comparison.

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Appendix A describes the manpower calculations. Table 1 sunmarizes these j

requirements. Eeactor technical support inspectors include all Pre-CP, t

i health physics, power reactor technical support and non-power reactor in:pectors.

i TABLE I IE MANPOWER FOR INSPECTION ALTERNATIVES FY 81 J

1 2

2 4

5 REGION

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Reactor Tech Support 370 362 275 175 275 LCVIP 39 39 39 39 39 Feel Cycle 63 63 63 63 63 Safeguards 90 90 90 62 90 Direction / Admin.

198 199 208 154 189 ONSITE Construction / Pre 0ps 0

3 62 62 62 Operations /Startup 0

10 71 426 71 Control Rcom 0

0 0

0 540 Admin. Support 0

0 0

71 71 SPECIAL TEAMS Inspectors / Analysts 0

120 120 120 120 Direction / Admin.

0 37 37 37 37 HEADQUARTERS Direction / Admin.

165 175 182 201 227 TOTALS 925 1098 1147 1410 1784

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I The estinated funding required to operate these alternatives in FY 81 t

is based on the IE Five Year Plan for Alternative 1 and computed l

additions to this amount for the other alternatives. Figure 2 shows the total FY 81 dollar requirenents for each alternative.

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5 ALTERNATIVES e

i Onsite Presence.

Each inspection alternative provides core presence onsite. The total hours are calculated in Appendix B and are sumsrized in Table 2.

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i-t, TABLE 2 TOTAL AfaUAL ONSITE PRESENCE (Thousands of Hours) 1 2

3 4

5 Current Site Full Time Continuous Contr i Program Vicinity Onsite___,

Onsite Room Region Inspectors 175.0 171.0 127.5 63.5 127.0 f

Site Vicinity or j

7.8 207.5 718.7 207.5 4

Onsite Inspectors 40.8 40.8 40.8 40.3 Special Teams 946.0 Control Room inspectors TOTALS 175.0 219.6 375.8 823.0 1321.2 Alternative 2 is only sligntly less costly (7%) than alternative 3 but yields only 60t as nany onsite nours. In addition, it applies these extra l

hours to a sampling of sites based on geographic tiot performance criteria.

While hours of presence are increased by this alternative, the frequency of s

presence is increased only at the clustered sites.

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Alternative 5 yields the greatest increase in onsite time,largely from control room inspections. H wever, it is about t,.fce as costly is the l

current program. More importantly, alternative 5 c.

not appear desirable because of the questionable inspectcr utility and because I

of potential interference with licensee responsibilities.

The most difficult choice is between alternatives 3 and 4.

The basic judgment involves the value of doubling onsite time versus the cost of 263 Odditional people. The additional expense woulu be warranted if the tinc could be 'ised productively (i.e., could increase confidence j

and could be a meaningful job for a highly cualified inspector). Since i

I alternative 1 already more than doubles the onsite tire spent in the current program, and since the full-time inspector in alternative 3 can i

cover all key licensee activities, it is unlikely that much more confidence would be gained by redoublir.9 the onsite time. F.rthermore, there is a limited amount of significant activity dur.ng non-prime shif ts f

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and it would be dif ficult to provide a challenging job for th*: inspectors.

On balar.:e, alternative 3 is preferred.

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3 SECTION IV CONCLUS!0NS While the current reactor inspection program has proved effective in determining that licensees have inglenented systens to control cen-struction, testing and operation, irorovenents could be nade to this prcgram that would prcvide a stronger basis for assuring that licensees are discharging their responsibi,ity to provide adequate -

protection of the public 5ealth and safety. These improvements would allow rore opportunity for directly verifying licer.see actions and for confirming the accuracy and conpleteness of licensee wrk and documenta-tion. In addition, increasing NRC inspector presence ensite would both heighten the licensee's awareness of fiRC requirerents and provide core occasion fcr assessing the effectiveness of licensee nanagement controls and the safety of licensed operations.

While each of the alternatives to tFe existing progran provides additinnal onsite tire and enhances tiRC's direct observatio.$/reasurernent capability. the Full lire Onsite alternative is oreferred. When fully inplemented, this alternative will double tie onsite tire pr1vided by the current progran with a 39% increase in inspector nanpowe" and a 30 increase in total progran costs. The Full Tire Onsite Inspection j

program will place fiRC inspectors in residence at nuclear sites under construction, in test and in operation. Dy the end of FY 1980, there i

will be at least one inspector on each site. Py the end of the follow-l ing year, additional inspectors will be stationed at sites with more than

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two reactors and at sites with reac*. ors in nore than one phase (construc-

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tion, test or operation).

1I Inspectors will naintain separate, govern.+nt-supplied office space

l ano adninistrative support. The onsite inspectors will concentrate on directly observing key licensee activities. Work area inspections will be randon and unannounced and may occur on non-prire as well as 3

prine shifts. Inspectors based in Regional Offices will perfere routine technical suoport inspections and will be available to the orsite

l inspector when specific technical assistance is required, in addition,

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special inspection teams will perforn periodic, unannounced critical reviews of licensee facilities to assess the effectiveness of the routir.e inspec-ll tion prograat and provide insight into the performance of onsite inspectors, j

t The Full Tire Onsite alternative applies uniforn inspection resources

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to all reactor licensees regardless of geographic location. Further-I nore, the total inspection progran provides a balanced perspective of ti licensee onsite activities; licensee nanagenent control systens as they ei f

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6 l'il are deronstrated by onsite operations; and the results of licensee actions. This alternative recognizes the inter-related nature of all licensee activities that impact on safety and affords each one an apprcpriate measure of inspection effort. The significantly increased I

direct observation that this program affords should yield increased infomition that c3n be fed back to the Office of Nuclear Reactor Regulaticn for evaluation and incorporatior into the licensing process.

It should be emphasized that this program will not change in any 1

way the relationsnips and responsibilities of the licensing offices l

(NRR and NP.SS) and IE for the safety of licensed facilities.

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While there are e.any benefits associated with the Full Time Onsite j

alternative, 'E recognizes that this alternative also risks compromise i

of inspector objectivity.

The inspection program will be structured to recognize that objectivity, particularly for resident inspectors, is difficult to maintain. Tna likelihood and consequences of loss of the resident inspector's objectivity will be compensated for in several ways:

By creating a job and career management program that is professionally and financially satisfying so that the motivation for loss of objectivity is reduced.

By selecting personnel of high caliber so that 1

professicnal and social pressure will work to counter loss of objectivity.

By verifying the good character of inspectar candietes I

t through backgrcund investigations.

By assuring tnat standards of conduct are specifically stated and clearly unders* cod by inspectors.

f Dy providing inspectors clear guidance as to their duties and limits of their authority.

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By close review of the work of inspectors, including onsite appraisals.

I By complenenting the efforts of resident inspectors with 2

additional inspections by regio.i-based inspectors and Special Inspection Teams under Headquarters control.

By routine transfer of resident inspectors on a periodic basis or early transfer if significant loss of objectivity is established.

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I The icplementation of thh arocram will also have an impact on the lg resource requirements of other NkC Officas. While these impacts are d

not fully evaluated as part of this study, several offices have

• t indicated that they anticipate additional workload under this program. The Office of Administration may require prompt aug-enta-tion to assist in recruiting and implementation. These additional requirements will be addressed as part of the implementation planning.

Initial estimates by the Offices of Administration and the Executive j.i 1.egal Director are that fewer than five people each will be required.

The Of fice of Nuclear Reactor Regulation estirates that they will require one additional person for each ten additional inspectors to continte both fornal and informal IE/NRR interaction. Other office requirements may be felt as soon as the increase in the IE we.-kforce has occurred.

Planning for the new progre:a nust include provisions for re-examining its basic conceot and effectiveness. While the details of this re-evaluation have not yet been defined. IE will develop a plan that identifies evaluation criteria and reasures. An initial re-evaluation will be e.sde within 18 months of program initiation.

Finally, while this study was directed to the reactor inspection program, there appear to be similar benefits that can be obtained at other major licensed facilities. IE will sponsor a follow-on study of other fuel cycle facilities to evaluate the application of resident inspection 1

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SECTION V k

IMPLEMENTATION introd;ction_

li In addition to a larger work force of the Office of Inspection and Enforce r.nt, implementation of alternative 3 involves a nutter of other factors that will ultimately detennine the success of the This section discusses the phased resource requirements program.

H necessary to achieve full implementation and identifies the planning tasks to be undertaken.

Resource Req 9irements - Phasinq a

The evaluation of the five inspection alternatives assumed steady d

state operation of the onsite inspection program by the end of FY 81.

By the end cf FY 80, at least one inspector will be assigned full-time to each site. To assure FY 81 implemntation, recruitment and training must begin as soon as possiole. Current estin.ates of the qualifications required for onsite inspectors and the available r.arket indicate that a new m.ployee must spend at least two years in the IE organization before onsite assignment. Even then, not all will qualify but inay spend additional time in a Regional Office to gain required experience.

The two years would be soent in formal training, parfor:ning regional inspections, and in OJT at a site. The requirement for this two year pipeline means that people recruited in FY 78 could not be placed

/

onsite or relieve a significant percentage of experienced inspectors for onsite assignments until FY 80. Since onsite inspector-in FY 78 and FY 79 must be drawa from existing inspector ranpoviar, not all s tes can be runned irriediately. However, several sites will be manned by the end of FY 77 and approximately 45 full time onsite inspectors will be in residence by tne end of FY 79.

The manpower requirements to phase into full irrplementation by FY 81 are shown in Table 3.

These requirenents wera derived based on the current forecast for licensing actions, a two-year pipeline for newly l

recruiteJ personnel, vol 'tary noves of a limited number of current f

inspectors, an attritter. ate of 5% for onsite inspectors and 15% for all others, gradual staffing of the special inspection teams and recruit sent in FY 78 of the training and administrative support personnel. A more detailed discussion of these factors is presented in Appendix C.

Using the FY 78 budget request and IE Five Year Plan as a baseline.

Table 4 shows the additional funding needed for phaf ed impitmentation.

The salary and benefits estimates are based on the au:ter of additional people each year, taking into account more frequent salary increases (step and prenotion) for new employees. The travel estimate is ba>ed

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h TABLE 3. PROJECTED PANPOWER DISTRIBUTION

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78 79 80 81 82 83 J ':; ~

REGION PERSONNEL

%.j ONSITE 35 46 111 133 152 153

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176 178 204 235 233 239

)~. ;d 20 33 37 39 39 39 4f TECHNICAL SUPPORT 24 LCVIP IN TRA:NING 122 192 101 40 72 92 b

FUEL CYCLE 60 61 62 63 65 66 O

• 4 y ",.)l SAFEGUARDS 53 71 75 90 98 112 DIRECTION & ADMINISTRAT10!i 147 174 180 208 244 254 i...!

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l REGION TOTAL 613 755 770 803 903 954

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SPECIS INSPECTION TEAMS u

INSPECTORS 27 50 74 97 97 97 o

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13 19 23 23 a

e ANALYSTS SUPERVISION & ADMINISTRATION 8

15 26 37 37 37 qq SPECIAL INSPECTION TOTAL.

42 78 119 157 157 157 IE HEADQUARTERS PANAGEMENT 52 52 50 54 56 60 PROGRAM DEVELOPMENT 84 105 127 128 128 123 9

i 136 157 177 182 184 188 HEADQUARTERS TOTAL I

I IE TOTAL 791 990 1.066 1,147 1.244 1,299 b'

Technical Support includes power reactor tech support, non-power reactor tech support, i,

Note: 1-and support for incident response and 10 CFR 21 additional inspection requirements.

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TABLE 4 ADDITIONAL BUDGET REQUEST j

Dollars (Millions) 7I l

78 79 83 81 82 83 1

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SALARY AND BENEFITS 2.0 3.5 5.8 6.0 6.3 6.6

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l TRAVEL 1.8 2.1 0.9 1.0 0.8 0.9 ADMINISTRTTIVE SUPPORT 1.0 2.0 2.3 2.3 2.4 2.5 i

S TRAINING 0.5 0.5 0.5 0.5 0.5 0.5 l

CONTRACTOR SUPPORT 0.5 0.5 2.0 2.0 2.0 2.0 i

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TOTAL 5.8 8.7 11.5 11.8 12.0 12.5 1

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on the norr.al additional travel for new personnel and the additional travel associated with OJT for newly recruited inspectors; moves of inspectors to site locations; additional travel to cover sith tempo-rarily until onsite inspectors are assigned; and the travel saved by placing inspectors onsite. Administrative support estimates are based on office facilities, equipment, supplies and services for the onsite inspectors. Training estimates are based or the additional courses thet will be conducted under contract. Finally, contractor support estinates involve costs associated witie valtdating the training and perscnnel qualifications / testing programs and providing additional confin.iatory measurements support.

Implementation Planning Implementation of an ensite inspection program will require prompt and decisive action on a number of key issues. Planning has already begun on some of these issues and, upon r. omission approval, an i

i intensive ef fort to tomplete them will be initiated. This effort will involve both Headqt.arters and Regional IE personnel as well as representatives from other NRC offices such as ELD, ADM and O!A.

Small teans will be fonted to estat,lish work plans and schedules and to complete the tasks. Key implementation tasks to be addressed in this effort are:

Onsite Manning Schedule Prcgrem Structure and Management Regional Organization Special Inspection Program inspection Duties Training Recruitment Career Management Conduct of Employees Onsite Logistics Support and Personnel Legal Aspects of Responsibilities and Authorities legal Aspects of Individual and Agency Liability impact on other NRC Offices Enforcement Program Licensee Impact Program Re-evaluation The following paragraphs identify the considerations to be addressed in each task.

Onsite Manning Schedul_e. Total IE resource reautrements for implementa-tion have Deen developed. Each Region must pr.rform a site-by-site analysis to identify:

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The order in which sites will be manned.

Those sites that can be manned without a physical move.

Those sites that can be manned by existing Region I

i personnel on a voluntary basis, The number of onsite inspectors by reactor phase i

required during FY 78 - FY 83.

The number of technical support inspectors required.

Results of the regional analyses must be consolidated and the total IE resource estimates must be allocated to the Regions.

A sumiry of resource needs by skill type for each Region must be developed for use by the training and recruitment t.ask forces.

pregran Structure and Managecent. The staff must develop guidance Tor acministering ano conducting the onsite, support, and special inspecticn programs that defines the authorities, responsibilities and roles of the Headquarters staff, regional onsite and technical support personnel and special inspection personnel. This guidance should cover the interplay among the components of the inspection progra'n.

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Supervision of remote, dispersed personnel must ensure adherence to inspection requirements. continued objectivity with respect to licensees and maintenance of inspector coepetency. There r:ust be a systen of checks and balances within the progran to ensure periodic in-depth examination of program effectiveness. This syten r:ust directly probe licensee control cystems and indirectly evaluate the performance of the onsite program.

The program must ensure timely reporting of significant items by onsite, technical support and special inspectors and timely attention to and disposition of these items by Regional and Headquarters ranage-ment. Regional onsite and special inspection experience must be incorporated into the program developeent process.

The program rust be well-defined to assure uniform treatment of cocparably perfonning licensees but permit enough flexibility to acccerodate different licensee facilities and performance. That is, the prcgram must be detailed enough to assure that there are no signif-icant differences in imple entation among the Regions, but flexible enough to respond to unexpected situations and to account for licensee and facility differences.

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.. g Regional Organization. The g wth and dispersecent of reactor inspectors

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and the adattion of a special inspection program may affect the number f]

of Regioral Offices, their internal organization or both. A task force will review these considerations, recognizing recent Comission interest E

in Regional expansion.

Special Irspecticn program. The special inspection prog-au must be structured to provice checks and t,alances to ensure the routine inspec-tion prcgram is oerfoming as intended. This component will bring a 1

perspective to the inspection program that is oriented toward the total control of licensed activities and transcends regional boundaries.

1 To achieve this, the perfomance appraisal and direct verificatinn/

measurement teams will conduct their activities from a support office reporting directly to the Director, IE.

q The appraisal teans will be led by experienced inspectors supplemented by staff rembers skilled in the disciplines required for the specific areas inspecsed. The teams will normally consist of three to five i

individuals who would spend about five days at a licensea facility.

The special inspection teams will possess independent measurement capability for verification of licensee performance. NRC inspectors supplerrented by contractor support will perform various measurements or activities for comparison with previous licensee measurenents nr activities. The direct verification /mcasurement capaitlity will also be available to the Regional Offices to enlarge their independent measurement activity.

In ' addition to appraising licensee perfomance, the results of special inspections will indicate the effectiveness of the onsite procram.

These inspections shoJld help maintain ins?cctor objectivity.

Duties of Onsite and Technical Support Inspectors.

The division of j

labor between onsite and regional technical support inspectors must ensure effective ar.d efficient usc of highly specialized technical support experts and of the onsite inspector generalists. The proo-am should raximize the ability to directly observe licensed activitict and perform sore confirmatory measurements but should not sacrifice the broad view of licensee operations obtained through the review of records.

A task force has ccepleted a first draft of onsite inspector duties for the construction, te.t and startup and operations phases. Upon Comission approval, the ensite duties will be refined and complementary technical 4

1 support daties developed.

In addition to the technical onsite duties, the authority and responsi-bility of the ins;ector must be defined. This task will be ccordinated with the legal censiderations, i

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l q Training. The qualifications required for onsite inspectors and the methocs of verifying these qualificaticns must be developed. Preliminary training estimates have indicated a two-year training period. The program builds on the current IE training and consists of classroom and simulator activities, on-the-jcb training and formalized self-study programs. The establishment of cour.:es, schedules and training require-j ments has begun and will accelerate upon approval.

Recruitment. To ensure smooth implementation, recruitment needs must

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be identified and coordinated with the sper.ific phasing require;nents and t.rainir.g schedules. Once needs are ir:entified, ai. aggrassive recruitment and personnel processing (including security clearances) i l

program must follow. Issues such as length of duty assignment, reassign-i I

ment considerations, reimbursement expenses for relocation and duty I

I hcurs must be defined for the nnsite program. New employees must ')e informed of policy concerning unsite assignment to minimize attrition.

Career Management. The onsite inspecci:n orogram will bring personnel

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at dif ferent age levels and with different knowledge and work experience to IE. To ass an work responsibilities and to provide a better approach

.o career development, several inspector classifications will be used.

These classifications, sequence of progression, grade levels and types of assignments must be estatlished in a career development path. Pra-I liminary work has begun in this area.

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Conduct of Er ployees. Assigning inspectors to often remote recctor

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sites presents a r.ew set of consideraticns with respect to the conduct p

of e ployeas. Particula-care must be given to avoiding any appear-o ance of or actual conflict of interest while minimizing personal sacrifices from inspectors or their families. ine NRC m'Jst re-examine k

the conduct expected of employees recognizir.g any legal constraints

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on employees; the impact that living in communities near licensed 1

facilities might have cn inspectors ar.d their families; and other g

potential problems that could result from moving toward the resident concept.

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Onsite Loaistics Support and Personnel Administration. The Trial r

Resicent inspection Program identifiec Icy stics support and personnel t

administration issues related to tne resident concept. These issues include space requirements, utilities, office equipment, transpor tation, reic W. ion reimbursement, administrative ass atance and leave and sick time. Region 111 has. identified a preliminar-list of considerations in tn:s area and will work with IE Haadcuarters and Administration perso nel to complete planning in th s area.

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Legal Aspects of Responsibilities and Authorities. An initial examina-tion of the provisions contained in the Atomic Energy Act indicates that the onsite inspection program would not be in conflict with the regulatory role of the NRC. The Act also provides authority for NRC to perform the necessary studies and investigations. However, changes to the regulations may be required to provide free and unaccompanied access to licensed facilities. A more detailed review of the applicable legisla-tio.1 and regulations is needed to determine whether all elements of alterna-tive 3 are consistent with NRC's responsibilities and authorities.

Legal Aspects of Individual and Agency Liability.

Although the duties of onsite and other inspectors have not yet been completely defined, they nay involve increased inspection re.iponsibility and flexibility.

If so, the fiRC and individual inspectors oey be open to incrcased liability with respect to interference in licensee operations. A careful assessment of the liabilities potentially incurred in this program must begin.

Impact on Other NRC Offices. The implementation and operation of alternative 3 will have resource impacts on other NRC offices. A nunber of of fices have identified preliminary estinates of the addi-tional manpower required as a result of the full time onsite program.

As part of the implementation planning, other NRC of fices must refine these estimates and determine the total resource ir. pacts on their programs.

Enforcement Program. The onsite program ray affect the enforcement program bJt the magnitude and nature of any impact hos not yet been determined. The resident concept and its implications for the enforce-ment program will be addressed in the on-going contractor and in-house studies of enforcecent and incentives.

Licensee Impact. NRC nust begin to inform licensees of the nature and intent of the onsite inspection program. Licensee feedback should be secured to minimize the impact on licensee operations.

program Re-evaluation. While implementation planning proceeds, a plan for evaluating program performance must also be developed.

This plan should identify criteria against which program performance can be measured and should specify the measures of performance to ba evaluated. An initial re-evaluation of the program should be perforned no later than 18 months after inspectors begin onsite assignments.

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APPENDICES t

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Fesource Requirerents for Alternativet 1-5 For evaluation purposes, full program implementation is assumed at the end of FY 81. The current reactor inspection program requires routine 1

and non-routine effort that is provided by project inspectors and tech-nical support inspectors. The amount of onsite time that is required g

varies by phase of the program. Table A-1 shows these requirements on an annual basis. Manpower requirements for the various alternatives are based on the inspection runhours required and on the nurrber of sites or reactors in various phases. Table A-2 shows the current forecast of l

facilities for the time frame considered.

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TABLE A-1 ONSITE REACTOR INSPECTIO.'i MANHOURS PER SITE PER YEAR CURRENT PROGRAM REQUIREMENTS Feactor Phase Prajectl Tech Support Non-Routine HP/Envir3 Total Pre Cp 60 30 0

0 90 Construction Single Reactor 170 260 70 0

500 2 Reactors 295 450 120 0

865 3 Reactors 420 640 170 0

1230 4 Reactors 545 830 220 0

1595 5 Reactors 6/0 1020 270 0

1960 2

Pre 0ps/ Reactor 0

535 135 210 880 2

Sta rtup/ Reactor 0

550 140 60 750 Operations Single Reactor 210 170 100 340 820 2 Reactors 315 255 150 510 1230 3 Reactors 420 3a0 200 680 1640 4 Reactors 525 425 250 850 2050 Note:

1.

Projects / Tech Support Ratios.ve:

4/.6 Construction

.55/.45 Operations 2.

Tro year period assumed for Prtops, one year for Startup.

3.

HP/Envir - Health physics radialogical protection and environmental inspections.

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ry-,- y, TAPI E A-2 REACTORS AND REACTOR SITES BY REACTOR PHASE FOR FY78-93

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J 1979 1979 igno 3 toot sqa2 tqa1 Sites Reactor Sites Reactor Sites! Reactor Sites l Reactor Site ktactor Sites Reactor i

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23 19 24 24 19 16 co 2

28 31 29 31 37 43 3

3 3

101 3

103 3

107 4

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112

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• 178 103 i

• The Sites per phase do not total to total sites due ts the mix of reactors by phase at various sites.

I The Site total corresponds to all sites that have reactors in any phase 2-5

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1 A-3 Table A-3 combines Tables 1 and 2 show the annual onsite nanhours required to accomplish the curr:nt program in FY 81. Non-routine workload has been included with technical support because it generally requires specific skills.

TABLE A-3 FY 81 ON3!TE REQUIREMENTS a

Non-Routine and H.P/

Project Tech Support Envir.

Pre-CP 3300 1650 0

Const 16540 31980 0

Pre-Ops 0

16080 5040 4

Startup 0

7590 660 Operations 18795 24165 30430 4

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Alternative 1: Current Program 1

Analysis of historical manpower data shows that one inspector typically provides 500 onsite man-hours per year. (Actual data for the past year shows 493 hours0.00571 days <br />0.137 hours <br />8.151455e-4 weeks <br />1.875865e-4 months <br />.) Dividing Table A-3 entries by this factor yields the number of inspectors needed to perform the current program (Tanle A-4).

In addition to this manpower, safeguteds inspectors are also required it The number shown is taken from the current Five-Year Plan.

power reactors.

1 TABLE A-4 4

FY 81 REACTOR INSPECTION MANPOWER i

Pre-CP 10 Const 97 Pre-Ops 32 15 j

Startup Operations 86 Environmental H. P.

72 Safeguards 38 TOTAL 350 6

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c This FY 81 projection of 350 it.spectors for power reactors is 23 less The difference than the projection in the current IE Five Year Plan.

L is because of the more detailed analysis of reactors by phase shown in I

Table A-2 was developed from a more recent Reactor Five Table A-2.

Year Forecast than was available when the Five Year Plan was submitted.

Alternative 2: Site Vicinity inspections t

The Trial Resident inspection Program recorrended locating an flRC inspector near clusters of three or more operating reactors within a radius of approximately 25 miles. The evaluation of the trial program further concluded that vicinity inspectors would be appropriate at a single or multi-unit facility during test and startup, and that nothing was identified to suggest that the concept would not be appli-cable to reactors under construction.

In alternative 2, vicinity inspectors tre considered when there are two or more sites in construction, test and startup, or operation within a radius of 50 miles. These criteria were chosen because single site multi-reactor inspectors are explicitly treated under alternative 3 and because the 50 mile radius is a reasoasole conmuting distance for periodic visits.

There are 11 clusters in FY 81 using these crittria. Of these, eight clusters will contain sites in operation only, and three will contain sites that have reactors in various phases of construction, pre-cp or These clusters are shown in Figure A-1.

startup testing, or operation.

Figure A-2 contains the geographical distribution of plants from which these clusters were selected. Resource calculations are based upon the two types of cluiters: mixed construction and operating reactors; and One vicinity inspector is placed at each pure operating reactors.

The workload

" pure" cluster ar.d two are placed at the " mixed" cluster.

accomplished by vicinity inspectors consist of three components (1) all g

current progran project type workload; (2) up to 50% of the current pro-gram technical support workload; and (3) direct observation and evaluation Regional manpower requirements are then based on of licensee activities.

the technical support workload that remains for these sites and the total workload for sites without a vicinity inspector, i

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t A-5 FIGURE A-1 SITE VICINITY CLUSTERS (t 50 mile radius)

Phase

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Browns Ferry 1-3 5

Bellefonte 1, 2 5

2.

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i Millstone 1-3 5

3.

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Zion 1,2 5

4.

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k'aterford 3 4

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Palisades 1 5

8.

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9.

Nine Mile Island 5

FitzPatrick 5

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Point Beach 1,2 5

11. Calvert Cliffs 1,2 5

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A -7 Table A-5 shows the nunter of inspectors required for this opticn.

TABLE A-5 J

l' INSPECTOR REQUIREMENTS - FY 81 " SITE VICINI]"

Regional Site Vicinity Inspectors

_ Inspectors Pre-Cp 10 0

Construction 96 1

Pre-Ops 30 2

1 l

Startup 13 2

l Operations 83 8

[

i Environmental 72 0

l Sa feguards 38 0

t' TOTALS 342 13 355 6.

Alternative 3: Full Time Onsite insoectors Tne required nurrber of onsite inspectors is derived from the nucher of sites with reactors in distinct phases as shown in Table A-2.

Inspectors are

+

placed at all sites where Pre-Ops (20) and Startup Testing (11) are in progress since these phases are very important check points. Some pre-I operational testing begins 18 months to 2 years prior to the issuance of 1

an operating license. Construction will still be in progress at these sites.

Thus, the number of construction sites (62) shown in Table A-2 includes the 20 pre-ops sites. In these cases it is assumed that the pre-ops inspectors will be able to cover tne construction work as well. This leaves 42 sites that have only construction in progress. An inspector will be stationed l

at each of these. In a similar fashion, when a plant is licensed there is I

a period of approximately one year for startup. The startup inspectors I

I will cover the operations activity at these sites. This leaves 60 sites where an operations inspectors must be located. This mix requires 133 inspectors at the 117 sites as shown in Table A-6.

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TABLE A-6 ONSITE INSPECTORS - FY 81 f

l' No. Reactors / Site 1

2 3

4 Total Construction 13 27 1

1 42

. f Preops Testing 18 1

0 1

20 4

Startup Testing 11 0

0 0

11 l

l Opera tions 34 22 4

0 60

' l 1

TOTAL 133 The regional manpower required to complete program workload can be estimated by subtracting the workload onsite inspectors accomplish f rom the total program requirements shown in Table A-3.

The remain-i ing workload is divided by 500 to obtain the number of regional support inspectors since regional inspectors spend close to 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> per year onsite. To obtain the regional workload, it was assumed that the onsite inspector for construction and operations sites couls perform all of the work ar.d 50% of the non-routine and technical support work. For the Preops and Startup phases, it was assumed that the onsit.- inspector could perform 75% of all the work except the health physics portion. The health physics specialty work would be totally based in the Regions. The onsite inspector would complete a

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naximum of 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> per year of the current inspection program.

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Using these assumptions with the location of the 133 onsite inspectors and Table A-1 data, Table A-7 shows the annual program requirements.

TABLE A-7 FY 81 INSPECT!0*l PROGRAM MANH0llRS Reactor HP/Envir Tech. Supp.

Tech. Supp.

Phase Total Hours Onsite Hour s Reofon Hours Inspectors Inspectors i

Const 48,520 12,415 27,105 54 0

Pre-Ops 21.120 10,060 11,060 17 6

i Startup 8,250 5,698 2,552 4

1 Operations 73,390 25,886 47,504 30 65 TOTALS 151,280 63,059 88,221 105 72 f

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9 A-9 in addition to the 177 inspectors shown above, the Regions require 10 inspectors for the Pre-CP workicad shown in Table A-3.

The Regions rnust also coordinate the work at the sites, regional inspections, training Headquarters assignments, and other liaison type activity. This wnrk will require travel to each site three times per year for one week. Since an I;l inspector can make 12 visits each year at 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per visit. one inspec-tor shoJld be able to handle 4 sites. For 117 sites, this would require 30 additional inspectors 11 for construction sites and 19 for operating sites. Table A-8 sunnarizes these requirements.

TABLE A-8 SITE AND REGION INSPECTOR REQUIREMENTS l

o mJLL TIME ONSITE - FY 81) j i

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Regional Onsite l

Inspectors Inspectors Pre-CP 10 0

l Construction 0

42 l

Pre-Ops 0

20 startup 0

11 l

Operations 0

60 l

Inspection Support

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Coordination 30 0

Tech Support 177 0

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Safeguards 38 0

TOTALS 255 133 388 i

Alter.iative 4: Continuous Onsite Inspectors 1

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Inspectar requirements for this alternative are also based upon the number j

of sites and the phase of each shown in Table 4-2.

Regional inspectors t

would continue to conduct all Pre-CP inspections. For reactors under l

construction or in preoperational test one shif t coverage is con."idered to suf fice, since these are basically single shif t operations. For reactors in these phases, the onsite inspectors would perform the same duties as l

their alternative 3 counterparts, t

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i A-10 For reactors in startup testing or in operation, three shifts of coverage are required. Onsite inspectors at these facilities would accomplish the complete reactor inspectio' program. Five inspectors would be required tn provide three-shift coverage. This is based on 21 shifts per week, S shif ts per inspector and needed overhead (leave, sickness, etc.) A supervisor is required for the five inspectors.

For startup and operations p5ases, this alternative does not require inspection support from the Regions, because the six inspector; assigned to each site could be chosen to include all the required expertise. Also, if one of the five inspectors is a health physicist and one is a safe-guards inspector, these two inspectors could accomplish the full reactor health physics and safeguards inspactions with no regional support. Site coordinators are still required in the Regions at the rate of one coordi-nator for four sites.

Table A-9 sumarizes the inspector nanpower requirements for this option.

T ABLE A-9 INSPECTOR REQUIREMENTS - FY 81 (Continuous Onsite)

Regional Onsite Inspectors inspectors pre-Cp 10 0

l l

Const 0

42 pre-Ops 0

20 Startup 0

66 Operations 0

360 Coordination 30 0

Tech Support 77 Safeguards 10 TOTALS 127 488 615

• H.P. and Safeguards inspectors included in startup and operations onsite teams.

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f Alternative 5: Continuous in Control Room As a ninircum, five inspectors are required to provide control room coverage i

for 21 shif ts per week. This estirate is conservatively low because it assumes one inspector can stand an eight hour shif t.

idhile this may be true, experience indicates that a four hour shif t is cure reasonable and 4

that nine inspectors are required. To remain conservative, this analysis considers only 5 control room inspectors per control room. In FY 81 4

there will be 108 operating reactors with 11 of these in startup testing.

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A control room inspector is assumed to be stationed at each reactor even though a control room ray be shared by more than one reactor, because of the current trend toward isolating reactor consoles. Continuous coverage i

for the 97 operating reactors requires 485 inspectors and similar coverag! for the 11 reactors in startup requires 55 inspectors. Since i

3 this option does not provide a means of conducting the routire frispec-tion program, but rather is designed to augment that prograr the control room inspector could be added to the baseline current program or to any of the alternatives. In practice, however, it is not reasonable to consider adding this option to any alternative other thar 1 because of resource implications. Table A-10 shows inspector requir?ments for alternative 3 (Table A-7) plus control room inspectors.

TABLE A-10 INSPECTOR REQ'JIREMENTS - FY 81 ONSITC CONTRCL R00:4 Regional Onsite Inspectors Inspectors l

Pre-Cp 10 0

Const 0

42 Pre-Ops 0

20 Startup 0

11 Operations 0

60 Control Room 540 Inspection Support Coordination 30 0

Tech Support 177 0

Sa feguards 38 0

TOTALS 255 673 923 l

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Appraisal inspections must be perfomed frequently enough to serve as a credible incantive. For resource estimation, one inspection per site par C

year for each reactor phase; co:1stru.. tion, preoperational or startup test, 7

[

or operation, represented at the site is assumed. Current program experi-ence suggest that a te.m may spend one week preparing for an inspection, one wee *, conducting the inspection an1 two weeks preparing reports and y

follow-up documentattm. Inspectors presently use approxic.ately 257. of f

available time for leat e, sickness, training etc., leaving 39. nan-weeks /

t I

year for inspection we kload. Each team, then, will be able to accomplish

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ten perfornance appraisal inspections per year. Table A-2 showed the nunter of sites per phase in FY 81. With one inspection per site and 10 annual inspection per team, Table A-11 shows the nutter of teams required.

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l TABLE A-11 6

APPRAISAL TEAMS - FY 81 1

l Const 6

y 1

C Pre-Ops 3

d y

Startup 1

Operaticns 7

W t

The comocsition of tne tecms will vary by piate. For construction sites, the team will consist of a leader, a quality assurance specialist, and i

.4 6

three (3) techn' cal specialists. For operations, a leader, an operations 3

i specialist and three (3) technical specialists are required. For pre-

'i operations and startup testing a leader and twc testing specialist will be j

required. Combining hble A-11 with these teams sizes yields Table A-12.

i TA3tE A-12 j

PERSONNEL REQUIREMENTS - FY 81 APPRAISAL TEAMS Const 30 1

Pre-Ops 9

j Startup 3

Operations 35

.y TOTAL 77

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B-2 by 400 onsite hours each. Confirratory measurement inspectors (20) are assured to provide as nany onsite hours per year as Regional inspectors, 500 each. Table 11-1 nerizes the total onsite hours provided by each type of inspector. The number of inspectors of each type is :hown in Appendix A.

l TABLE 11-1 ANNUAL ONSITE HOUP" BY TY'ES OF INSPECTOR (FY 81) 1 2

3 4

5 Current Site Full-Time Continuous Control Program Vicinity Onsite Onsite Room Regionil Inspectors 175,000 171,000 127,500 63,500 127,000 7,800 Site Vicinity inspectors 207,480 95.720 207,480 Onsite Inspectors 621,960 Continuous, Startup/ Operations 946,080 Continuous, Control Room 30,800 30,800 30,800 30,800 Perfor-ance Appraisal 10,000 10,000 10,000 10,000 Confir-atory Measurement TOTALS 175,000 219,600 375,780 822,980 1,321,360

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,f U ? T 97' y PHASED 1%Np0WER'- ALTERNATIVE 3 A M._

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_'_ l-l > &Qj..m It is estimated'th'at 18 sites are located close enough to the Regional'

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Offices to provide an onsite inspector without a physical move of the N

would be arenable to a; move to an onsite location in FY 78, 'Thus, 35

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inspector's home.;i t is further estimated that 17 current inspectors s1 '. c l

'fW (of 98) sites could be covered by full-time onsite inspectors in FY 78.

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b Assuming two (5%) of these inspectors are lost to attrition in FY 79 and that 13 more move to the sites, 46 sites (of 103) could be ~

12r covered in FY'79. :In FY 80, the first group of recruits will become 3

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eligible for onsite assignment. Assuming two onsite inspectors are

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again lost to attrition, moving 67 of these two-year inspectors will

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provide fJil time onsite coverage at each of the 111 sites..In FY_81 -

27 cuves will be ~ required to replace attrition and bring the onsite inspector force to the 133 inspectors needed for 117 sites. Onsite staffing for future years then becomes a matter of replacing attrition

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and satisfying new requirements.

At the er.d of'FY 77,'t'here will be approximately 153 reactor operations

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and construction inspectors (excluding non-power reactor inspectors and health physics inspectors) on board in the Regions. It is estimated that 15% of this workforce will be lost to attritten each year (except ri those assigned onsite). This attrition, coupled with the placement of I

35 of those inspectors onsite in FY 78 and 13 more in FY 79, causes significant reduction in the experienced workforce in the Regions which must provide technical. support and coordinatic:. for onsite inspectors.

A nurber of inspectors must be recruited in FY 78 to supplement those remaining from the current workferce and bring the regional support ins;;ector strength back up to the level required for full implementation in FY 81.

In addition to phasing in the inspectors required for onsite and regional duty, the training organization must be staffed to cope with an increased training workload; the special inspection teams must be built and appropriate Headquarters and Regional a'.ministrative support must be added. To attain implementation by FY 81, the training staff must be augmented inricdiately (13 positions Appendix A). Also the ten administrative support positions in the Regions and the four Head-I 7

quarters positions identified in Appendix A must be added in FT 78 to handle the influx of new employees and the administrative details

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