ML20057C026

Provides Commission W/Results of Assessment of Operating Reactor Insp Program for FY93

ML20057C026
Person / Time
Issue date:	08/25/1993
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-93-241, NUDOCS 9309240299
Download: ML20057C026 (29)

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August 25, 1993 SECY-93-241 l

FOR:

The Commissioners FROM:

James M. Taylor Executive Director for Operations SUBJECl:

FINAL REPORT ON THE RESULTS OF THE FISCAL YEAR 93 ASSESSMENT OF THE EFFECTIVENESS AND IMPLEMENTATION OF THE OPERATING REACTOR INSPECTION PROGRAM PURPOSE:

To provide the Commission with the results of the staff's assessment of the operating reactor inspection program conducted during Fiscal Year (FY) 1993.

SUMMARY

During FY 93, the staff performed an assessment of the effectiveness and implementation of the operating reactor inspection program. The results of the assessment indicate that the program is generally effective in meeting its regulatory objectives, evaluates appropriate areas, and results in identification of significant issues and adverse trends in licensee performance.

However, several areas were identified where changes are necessary to improve program effectiveness. Major improvement actions will include: 1) revision of the inspection program to facilitate improved allocation of inspection resources based on licensee performance; 2) gradual reductions in overall inspection effort from improved allocation of inspection resources based on licensee performance; 3) improved guidance and implementation of NRC management oversight activities; and 4) increased inspection focus on licensee management programs such as root cause analysis, corrective action, and self assessment.

Program enhancements will also include changes to reflect revisions to the SALP process, issuance of a revised maintenance inspection procedure that correlates with the maintenance CONTACT:

NOTE:

TO BE MADE PUBLICLY AVAILABLE R. Johnson IN 10 WORKING DAYS FROM THE DATE OF THIS PAPER

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i rule, issuance of a core inspection procedure in the area of engineering and j

technical support, and incorporation of other pertinent changes or lessons j

learned from the assessment.

Program changes are expected to be completed by i

December 1993.

BACKGROUND:

On May 8, 1992, the staff forwarded SECY-92-169, "The Staff's Progress on Actions to Improve Independent Assessment of the Inspection Program," to identify inspection program objectives and the specific measures the staff intended to use in assessing the effectiveness of the operating reactor inspection program.

In November 1992, the staff completed the development of a process to periodically assess the inspection program. This process, documented in the

" Guide to the Assessment of the NRC Reactor Inspection Program," incorporates the initiatives described in SECY-92-169 to place increased emphasis on performing quantitative and qualitative analyses of the inspection program.

The guide was forwarded to the Commission in a memorandum from J. Taylor on the assessment of the reactor inspection program (OPP-92-01), dated April 13, 1993. The objectives of the inspection program assessment process are to evaluate if the inspection program 1) is effective in achieving its regulatory objectives, 2) looks at appropriate areas, 3) devotes resources at a level consistent with industry performance, and 4) is implemented consistently on a national basis.

The assessment process evaluates the overall effectiveness and execution of the inspection program in each region.

Each assessment consists of preliminary in-office analysis of inspection-related data and results, visits to two reactor sites, a one week visit to the regional office, and post-visit analysis. Upon completion of each regional visit, ratings are assigned to discrete assessment elements. Assessment element results are then evaluated to determine the effectiveness of the inspection program in the region and the quality of regional execution in the areas of management oversight of inspectors and program activities, planning of inspections, and documentation and communication of inspection results. The results of the assessment are displayed graphically in an inspection program assessment tree.

Following completion of visits to all regions, the results are integrated to arrive at overall conclusions regarding program effectiveness and execution and to identify any necessary program improvements.

Beginning in December 1992, the Office of Nuclear Reactor Regulation (NRR) conducted assessments of the effectiveness and execution of the operating reactor inspection program for FY 92. The major conclusions and improvement actions are summarized below. The detailed results for each assessment i

element and a completed tree that indicates national ratings assigned to each assessment element are enclosed.

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DISCUSSION:

INSPECTION PROGRAM EFFECTIVENESS The inspection program was generally effective in achieving its regulatory objectives in support of the NRC's mission. However, several areas were identified where changes to enhance program effectiveness are to be developed and implemented.

The combination of core, regional initiative, and area of emphasis inspections focused on the appropriate areas and provided accurate insights regarding individual licensee and industry performance. The inspection program identified emerging safety issues and significant declining trends in performance and focused increased inspection effort to verify that licensees resolved issues before performance declined below an acceptable level.

At good performing plants, core program activities alone were effective in identifying declining licensee performance.

Because good performing licensees experienced fewer events and usually had strong self-assessment and corrective action programs, the inspection staff was able to focus inspection effort on potential problem areas. Area of emphasis team inspections and regional initiative inspections supplemented core activities and served to validate the accuracy of insights provided through core activities.

At average to poor performing plants, core program activities were generally effective in identifying or following up issues that were often the first indication of declining licensee performance.

Regional initiative inspections played an important role in the identification and follow up of significant issues. Once significant adverse trends in licensee performance were identified, the regions supplemented core program activities with team inspections and other regional initiative inspections, meetings with licensee management, and other regulatory activities to ensure that licensee management recognized and effectively resolved significant issues. Most regions established panels of regional and headquarters managers to coordinate NRC activities to evaluate licensees' plans and schedules for performance improvements and determine the proper focus, scope, and timing of inspections at poor performing pl&nts.

i The regions were particularly effective at responding to significant issues or events through the use of Augmented Inspection Teams or other reactive i

inspections.

These activities identified the root cause(s) and verified that i

licensees initiated appropriate corrective actions.

In addition, the inspection program was effective in identifying issues that had potential generic significance.

These issues were subsequently communicated to other i

regions and to headquarters, l

1 Despite the overall effectiveness of the inspection program at achieving established goals, several areas required improvement.

In many instances, inspection resources devoted to individual reactor licensees were not consistent with licensee performance.

In addition, inconsistencies were found between the level of inspection devoted to similarly performing plants, both within the regions and nationally.

For example, inspection devoted to several

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dual unit sites with identical systematic assessment of licensee performance (SALP) ratings varied by over 2000 inspection hours in FY 92.

While many of these inconsistencies were the result of inspections conducted to appropriately follow up on emerging events, issues, or adverse trends in licensee performance, others did not appear to be necessary.

Inspection program adjustments are necessary to improve consistency. These adjustments, along with adjustments to reduce budgeted resources for area of emphasis inspections in order to reflect historical expenditures, are expected to result in overall reductions in the inspection program. Although these adjustments should not reduce overall program effectiveness, the staff will closely monitor trends in licensee performance to detect any adverse effect.

The assessment indicated that overall effectiveness of the inspection program was highly dependent upon the skills and performance of individual inspectors and the quality of management oversight.

In several cases, long-standing performance problems were identified as the result of rotation of assigned resident inspectors. This finding reinforces the importance of NRC management in ensuring inspector objectivity and overseeing inspector performance.

The core program did not focus sufficiently on inspection of licensee activities in the areas of Engineering and Technical Support (ETS) and Safety Assessment and Quality Verification (SAQV).

Historically, licensee performance lagged in these areas, yet the core inspection program devoted the least resources in ETS and SAQV. The staff previously recognized that the core program did not provide for sufficient inspection effort in the area of ETS and initiated the development of a revised core inspection procedure. The regions had supplemented core inspection effort through regional initiative and area of emphasis inspections.

INSPECTION PROGRAM EXECUTION Execution of the inspection program was satisfactory in all regions.

Regional management effectively identified lessons learned as a result of events and inspection findings, and provided feedback to headquarters and to other regions.

Regional managers ensured that sufficient staff was available to implement the requirements of the inspection program and that inspectors received necessary training. However, most regions did not consistently i

implement the requirements for management oversight of inspectors. Although managers generally achieved the requirements for the frequency and duration of oversight visits, some managers did not routinely observe inspector activities or seldom provided feedback. Current requirements for management oversight of inspectors in the field were established to improve inspector professionalism i

and performance. The deficiencies indicated that continued improvements are necessary.

I The regions established and maintained inspection plans for each site and adequately coordinated the scheduling of team inspections and other major NRC i

non-inspection activities conducted at reactor sites with major licensee and third party activities.

Effective planning and follow up by regional management ensured that required inspection activities were conducted at all sites.

In addition, all regions used Plant Performance Reviews (PPR) to identify trends in licensee performance and to adjust planned inspection

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effort to address emerging problems.

However, the PPR and other planning processes focused on specific plants without providing a more integrated look at inspection resource allocation versus plant performance across a region.

This resulted in the regions being less effective at directing or redirecting regional initiative and reactive inspections from plants with better performance to plants with poorer performance.

Consequently, in several instances, a lack of correlation existed between licensee performance and inspection effort.

The regions conducted inspection activities in accordance with program requirements and identified issues that were significant to plant safety.

Most inspections were performance-based and resulted in the identification of appropriate findings.

These included inspections to follow up on events, generic area team inspections, and other in-depth initiative inspection activities. However, in some instances, routine inspections were conducted in a programmatic manner and resulted in the identification of few findings.

More performance-based inspections would likely have yielded different results.

In addition, in many regions routine resident observations of maintenance and survanlance testing lacked thoroughness or substance.

Several regions initiated 9fforts to strengthen region-based inspections by conducting small group inspet! ions focused on a particular area of licensee performance. Continued managemect emphasis is necessary to ensure that all routine inspection activities are implemented effectively.

The regions emphasized onsite inspection of licensee activities and effectively matched the capabilities of inspectors to required inspection tasks.

Regional success in achieving desired onsite inspection effort varied, with two regions consistently exceeding program goals and the other three regions falling short of program goals.

Inspection reports contained clear and concise safety significant findings that were well supported by facts and references.

Inspection report forwarding letters provided clear messages to licensees regarding the NRC's perception of the significance of identified concerns. However, improvements in report format and timeliness were necessary.

MAJOR IMPROVEMENT ACTIONS As a result of the assessment, the staff is proposing the following improvement actions.

Modify the existing inspection program to facilitate improved consistency of level of inspection effort by establishing a flexible goal for inspection effort expenditures based on licensee performance.

Reduce overall inspection effort. The amount will be based on projected savings from a better correlation of inspection resources to licensee performance and on savings achieved by reducing allocated resources for area of emphasis inspections in order to reflect current inspection needs and past expenditures, i

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Incorporate lessons learned from the assessment into the~ inspection program.

For example, modify observations of licensee activities to emphasize observations of significant licensee activities, rather than attaining quotas.

Monitor trends in licensee performance to detect possible declining performance due to the reductions in the inspection program.

Improve guidance and implementation of NRC management oversight activities and increase management emphasis on activities intended to ensure performance and objectivity of inspectors.

Revise the core SAQV inspection procedure to provide increased inspection focus on licensee management programs, such as root cause analysis, corrective action, and self assessment. Additionally, issue a core inspection procedure in the area of ETS and increase inspection effort allocated to both areas.

Improve implementation of the Plant Performance Review (PPR) process and other planning processes to better match available inspection resources with licensee performance on a regional basis.

The inspection program will also be revised to reflect revisions to the SALP process, to provide issuance of a revised maintenance inspection procedure that reflects the new maintenance rule, and to incorporate any pertinent changes recommended in other inspection program assessments.

In its SRM dated May 6,1993 (M930423D - Briefing on Assessment of NRC Inspection Program), the Commission directed the staff to consider several t

questions in evaluating the actions it would take to enhance the inspection program, including how the staff will measure the impact of reductions in inspection resource levels. Current plans are to reduce total inspection resources, including direct inspection, program development, and overhead, by 1

five percent in FY 94 with an additional reduction of two percent in FY 95.

Further reductions are being considered as a result of the inspection program assessment. The staff believes there will be no adverse consequences as a result of these reductions. However, we will continue to monitor existing performance measures to ensure that reductions do not result in a negative impact. This includes the review of plant specific performance measures and evaluations such as performance indicators, LERs, enforcement trends, PPRs, i

semi-annual Senior Management Meetings, and SALP.

In addition, NRR will

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continue to perform periodic assessments of the effectiveness of the inspection program. The staff will address the remaining questions raised by the Commission in its May 6,1993 SRM along with providing the status of implementing the inspection program enhancements described in this paper in December 1993.

s es M. Tay r xecutive Director for Operations

Enclosure:

Assessment of the NRC Operating Reactor Inspection Program DISTRIBUTION:

Commissioners OGC OCAA OIG OPA OCA OPP REGIONAL OFFICES EDO ACRS SECY 1

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Enclosure ASSESSMENT OF THE NRC OPERATING REACTOR INSPECTION PROGRAM DETAILED RESULTS 1.

CORE INSPECTION PROGRAM The effectiveness of the core program was rated: SatisfaClory.

The effectiveness of the core inspection program was evaluated for plants identified as NRC Poor Performers to NRC Good Performers.

For poor performing.

plants, the evaluation focused on determining whether the core program resulted in the discovery or follow up of issues that led to a decline.

For the good performing plants, the evaluation focused on determining whether the performance of the core program alone was effective in providing sufficient insights regarding licensee performance. Also, an evaluation was conducted of whether the core program devoted a sufficient, but not excessive, level of inspection effort based on industry performance and whether or not the core program was implemented consistent with the program guidelines.

The core program effectively provided early identification or follow up of significant adverse trends in licensee performance before they experienced a significant decline.

In addition, the core inspection program provided accurate insights regarding licensee performance at good performing plants.

In general, the core inspection program was focused on the appropriate areas to verify that licensees operate their facilities safely. However, the core program did not focus sufficiently on inspection of licensee activities in the i

areas of ETS and SAQV. A redistribution of core inspection resources will be made accordingly.

i Although the core inspection program was intended to provide a consistent level of inspection at all sites, inspection hours expended on core program activities varied from plant to plant and from region to region. The effectiveness of core program activities was dependent on the skills and performance of individual inspectors to correctly identify and evaluate deficiencies in licensee activities that were indicative of adverse trends in performance.

t 1.1 IDENTIFICATION OF SIGNIFICANT ISSUES BEFORE THEY BECOME SELF-REVEALING FOR PLANTS WITH A SIGNIFICANT DECLINE IN PERFORMANCE The ef fectiveness of the core inspection program was evaluated with respect to its ability to identify and develop significant issues for plants that have experienced a significant decline in performance.

Core inspection activities were reviewed for eight facilities that were listed on the NRC Problem Plant

2 List or had experienced a significant decline in performance.

In general, results indicated that the core inspection program, in conjunction with other inspection program activities, was effective in identifying and following up on significant issues that were indicative of declining licensee performance.

However, at one plant, the core program was not fully effective in identifying a pervasive problem.

During licensed operator requalification examinations at tnis facility, a weakness was discovered in the licensee's ability to implement the Emergency Operating Procedures (EOP). This ultimately resulted in the identification of a major decline of licensee performance from a SALP rating of Category I to 3.

The core program as structured did not direct inspectors toward identification of this problem.

In all regions, the effectiveness of the core program was found to be highly dependent on the performance of the inspection staff and the quality of management oversight of inspectors.

Several examples were identified where the rotation of the resident inspection staffs was a key contributor to the identification of long-standing licensee performance problems.

Because the core program relies on limited selective examination of licensee activities and programs to provide early identification or follow up of issues and events, its effectiveness was dependent upon the ability of individual inspectors to properly recognize and evaluate safety concerns and raise them to managers and licensees for resolution. This highlights the importance of enhancing management oversight activities. Such activities include observation of inspectors in the field, activities to ensure inspector objectivity, and the integration of multiple inspection insights in evaluating trends in licensee performance.

In all of the regions, once NRC management recognized declining performance, follow up inspections, management meetings with the licensee, and other NRC activities were used effectively to focus licensee attention on the issues and to obtain proper resolution.

Overall Rating: SATISFACTORY.

1.2 ADEQUACY OF THE CORE INSPECTION PROGRAM FOR PLANTS THAT ARE " GOOD PERFORMERS" The results of core inspection activities at a total of seven plants that were designated as NRC " Good Performing Plants," or had similarly good performance were evaluated.

Because the inspection effort at good performing plants is largely comprised of core inspection program activities, this element evaluated whether the core program alone was effective in identifying significant issues and providing insights regarding licensee performance.

In addition to reviewing inspection reports that documented core inspection activities, findings of significant non-core inspections conducted at these facilities were evaluated to determine if they identified issues that should have been found through performance of core inspections, but were not.

The overall effectiveness of the inspection program at good perfonning plants was a significant strength.

The core program led to successful identification or follow up of significant issues at all of the facilities evaluated.

3 Because good performing licensees experienced few events and had strong self-assessment and corrective action programs, the inspection staff was able to better focus inspection effort on potential problem areas.

Major non-core inspection activities performed at good performing plants such as the Electrical Distribution System Functional Inspection at St. Lucie, the Emergency Operating Procedures review at Susquehanna, and the Instrumentation and Control Team inspection at Diablo Canyon did not identify any significant issues that should have been identified by core inspection activities.

Overall Rating: SIGNIFICANT STRENGTH.

1.3 CONSISTENCY BETWEEN CORE INSPECTION EFFORT EXPENDED AND INDUSTRY PERFORMANCE This element evaluated the correlation between licensee performance by SALP functional area and the core inspection program effort to determine.whether the level of core inspection effort was commensurate with industry performance. The following table displays the estihated core program hours from the guidelines established in the Inspection Manual Chapter (IMC) 2515,

" Light-Water Reactor Inspection Program-Operations Phase," the expended core inspection hours (national), and the average national SALP ratings for each SALP functional area in FY 92.

SALP ESTIMATED ACTUAL CORE AVERAGE t

FUNCTIONAL AREA CORE HOURS INSPECTION HOURS SALP SCORE Emergency Preparedness 6,580 10,212 1.3 Security 5,504 5,230 1.3 Operations 64,388 93,438 1.6 Radiation Controls 11,696 14,086 1.6 Maintenance / Surveillance 22,470 34,550 1.8 Safety Assessment /

3,096 6,424 1.8 Quality Verification Engineering / Technical 3,360 5,392 1.9 Support Based on the current performance of licensees in all regions and a review of historical SALP data, the core inspection program model should place greater emphasis in the areas of SAQV and ETS relative to the other areas.

The core model allocated approximately two percent of the total core inspection program effort for the functional areas of SAQV and ETS and the regions expended four percent in both areas. The staff previously recognized that the core program did not provide for sufficient inspection effort in the area of ETS and, as a result, initiated the development of a revised core inspection procedure to

'i provide increased inspection effort in the engineering area. The regions had increased inspection effort in ETS to supplement the core program.

In the area of Emergency Preparedness (EP), overall licensee performance was considered to be good. However, a significant amount of inspection effort was expended by the regions in this area. The NRR staff recognized that

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disproportionate effort was being expended in the area of EP and initiated changes to the core inspection program to reduce inspection allocation.

In addition to looking at resources devoted to specific areas, the actual level of expenditures were compared with the expected level of expenditures recommended by the core model. The regions did not expend inspection resources consistent with the core budget model. Only one region closely followed the inspection effort estimated for the core program. This was accomplished through close control of inspection activities by regional management.

A detailed review of the inspection program to identify those activities that are required to adequately evaluate licensee performance in each functional area. A redistribution of core inspection resources will be made to reflect the results of this review.

Overall Rating: NEEDS IMPROVEMENT.

1.4 CONSISTENCY OF CORE INSPECTION EFFORT FROM PLANT TO PLANT Inspection data from the Regulatory Information Tracking System (RITS) for FY 92 was reviewed to evaluate the consistency of core inspection effort between plants. The structure and content of the core program provides a base level of inspection for similar sites, regardless of licensee performance.

Although some variations are expected from plant to plant, the level of inspection for similar sites should generally be consistent.

On a national basis, considerable variations were found to exist between the effort expended at sites with a similar number of reactors and the estimates established in IMC 2515. The following table displays the core model hours recommended by the core program and the range of core hours expended for sites across the nation.

CORE MODEL HOURS RANGE OF EXPENDED HOURS PER SITE PER SITE Single Unit 1453 1343-2955 Double Unit 1816 1468-3971 Triple Unit 2179 2725-3366 As discussed in Element 1.3, some of the inconsistency was due to underestimation of inspection requirements by the NRR core program model.

Additional inconsistencies were due to regional weaknesses in implementation of core program inspection activities, including management, planning, and documentation. This was highlighted by the considerable success of one region in managing and controlling core inspection effort in accordance with program recommendations and then closely controlling the additional inspection effort

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as regional initiative necessary to adequately evaluate the licensee's performance.

Program adjustment to make resource estimates better reflect core program requirements and increased management focus on core program utilization are necessary to improve consistency.

Overall Rating: NEEDS IMPROVEMENT.

2.

INITIATIVE INSPECTION PROGRAM The effectiveness of the regional initiative inspection program was rated:

Satisfactory.

The regional initiative inspection program was evaluated to determine whether initiative inspections were used effectively to supplement core and area of emphasis inspections in identifying and pursuing significant issues and appropriately following up events.

This area evaluated whether inspection findings and enforcement actions provided sufficient insights to enable regional and headquarters management to identify significant declines in performance for poorly performing plants.

This area also evaluated whether the overall inspection program devoted a sufficient (but not excessive) level of inspection effort based on licensee performance and whether the inspection effort was consistent for licensees with similar performance.

The overall level of regional initiative inspection effort was appropriate.

However, regional initiative inspection effort was frequently not consistent for similarly performing plants, both within the regions and nationally.

Despite these inconsistencies, the initiative inspection program, with the support of other NRC activities, provided for the identification of licensee weaknesses before overall plant performance declined for poorly performing plants.

The NRC responded promptly and effectively to significant events.

The regions quickly and properly characterized the significance of events and initiated appropriate follow up inspections.

1 2.1 CONSISTENCY OF INITIATIVE EFFORT EXPENDED WITH INDUSTRY PERFORMANCE f

This element evaluated whether the regions effectively controlled regional initiative inspection effort to ensure that initiative inspection activity was appropriately focused based on licer.see performance.

SALP ratings in each functional-area were compared with inspection effort devoted to these areas.

The regions had varying degrees of success in ensuring the initiative inspection was consistent with licensee performance within the region. One region was very successful in attaining this balance.

For example, in this region, three licensee facilities with declining performance received the highest amount of regional initiative inspection effort while other licensee facilities with good performance received the least amount of regional initiative inspection.

Two regions were not as successful in this area.

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example, in one region a licensee identified as an NRC Problem Plant received less inspection effort than several average performing and some good performing facilities. Also, several plants with SALP Category I ratings received more inspection effort than plants with SALP Category 2 ratings in the same area.

Several of these variations were justified.

For example, variations of inspection effort between similarly performing plants were due at times to the regions and headquarters conducting reactive inspections to respond to events, emerging issues, or major plant activities.

Despite the success achieved by some regions in maintaining consistency between performance and inspection effort at a regional level, inspection effort devoted to similarly performing licensees in different regions varied widely.

For example, in FY 92 the inspc:. tion effort devoted to dual unit plants on the NRC list of good performing plants varied from 3205 hours0.0371 days <br />0.89 hours <br />0.0053 weeks <br />0.00122 months <br /> to 5207 hours0.0603 days <br />1.446 hours <br />0.00861 weeks <br />0.00198 months <br />. Also, inspection effort for five dual unit plants in various 1

regions with identical SALP ratings in every functional area, varied from 3416 hours0.0395 days <br />0.949 hours <br />0.00565 weeks <br />0.0013 months <br /> to 6816 hours0.0789 days <br />1.893 hours <br />0.0113 weeks <br />0.00259 months <br />.

Adjustments to the inspection program to clearly establish flexible goals for inspection effort expenditures based on licensee performance will facilitate improved consistency of level of inspectiol effort within and between the regions.

Overall Rating: NEEDS IMPROVEMENT.

2.2 IDENTIFICATION OF LICENSEE MANAGEMENT CONTROL SYSTEM WEAKNESSES BEFORE OVERALL PLANT PERFORMANCE DECLINED FOR P0ORLY PERFORMING PLANTS i

This element evaluated whether the inspection program effectively identified weaknesses in licensee management control systems before overall plant performance underwent a significant decline (SALP 1 to 3 in any area or t

placement on the Problem Plant List). The effectiveness of the inspection program at Brunswick, Fitzpatrick, Zion, Dresden and WNP-2 who met the above criteria and South Texas, Cooper and River Bend who demonstrated adverse trends in performance was evaluated.

In general, the inspection program was effective in identifying weaknesses in licensee management control systems before plant performance declined.

For example, at Fitzpatrick the inspection staff provided early identification of significant weaknesses in licensee performance.

These weaknesses were reflected in SALP reports and subsequently confirmed by a Diagnostic Evaluation Team.

Regional initiative inspections, in conjunction with other NRC activities, 3

were effective in identifying weaknesses in licensee management control 4

7 systems that signaled declining licensee performance. Once adverse trends were identified, the inspection program and other regulatory activities, including PPRs, Senior Management Heetings, SALP, and meetings with licensee managers were used effectively to focus licensee attention on resolving deficiencies.

Overall Rating: SATISFACTORY.

2.3 CORRELATION BETWEEN ENFORCEMENT HISTORY AND DECLINE IN PLANT PERFORMANCE FOR POORLY PERFORMING PLANTS This element evaluated whether a correlation existed between escalated enforcement history and plant performance for poorly perferming plants.

A review of the escalated enforcement history for the pirats listed on the NRC Problem Plant List was performed.

Within the scope of the review, the number of escalated enforcement actions did not predict declining licensee performance. Two of the five plants on the NRC Poor Performer List did not have any escalated enforcement actions prior to the identified decline in performance. One plant had one escalated enforcement action and the other two plants together had ten escalated enforcement actions with an additional four escalated enforcement actions pending.

Future assessments in this area will review both escalated and non-escalated enforcement history for poorly performing plants to identify correlations between enforcement and performance.

Overall Rating: SATISFACTORY.

2.4 USE OF REACTIVE RESOURCES TO APPROPRIATELY RESPOND TO SIGNIFICANT ISSUES / EVENTS An evaluation of regional reactive inspection efforts was conducted to determine whether the regions effectively used reactive resources to respond to significant events and issues.

The use of reactive resources was a significant strength in all regions. The regions promptly and correctly evaluated the significance of events and conducted Augmented Inspection Team (AIT) inspections when appropriate to evaluate short and long term licensee responses. Thirteen AITs were dispatched to commercial power reactor facilities during FY 92.

For example, an AIT at Salem reviewed a turbine overspeed failure and discovered that the licensee had no preventive maintenance program for the valves that failed, the testing of the valves was inadequate, and an opportunity for early licensee identification of the valve failures went uncorrected due to miscommunication. An AIT at Palo Verde reviewed a three day loss of annunciators and computer alarm systems.

The AIT discovered that electricians did not take appropriate electrical safety precautions to prevent

8 accidental damage to equipment, they performed work that was not specified by the work order, plant operating procedures did not cover a complete loss of annunciators, and operators were not trained for a complete loss of annunciators during normal and abnormal conditions. An AIT at Millstone reviewed a moisture separator reheater drain line rupture. The AIT confirmed that inadequate erosion / corrosion monitoring programs are not identifying all piping susceptible to this phenomena, and that erosion / corrosion is multi-variable and exclusion of piping systems from analysis, inspection, and monitoring based on one variable may not be appropriate.

The regions also responded aggressively to events or' issues that did not reach the threshold for requiring an AIT.

For example, Region II sent two resident inspectors to Turkey Point before Hurricane Andrew to staff the emergency operating facility (E0F) in Miami for nine days after the hurricane and to conduct extensive inspections before restart.

The regions obtained good results from reactive inspections by focusing on problems and assigning qualified staff to thoroughly investigate issues to their root cause(s).

Overall Rating: SIGNIFICANT STRENGTH.

3.

AREA 0F EMPHASIS INSPECTION PROGRAM The area of emphasis inspection program was rated: Satisfactory.

Area of emphasis inspections were evaluated to determine whether safety issues and generic area team (GAT) inspections effectively focused on emerging generic safety issues, and whether these inspections resulted in the identification of significant issues. The effectiveness of the inspection program in following up on issues that were potentially generic and communicating the findings between the regions and with headquarters was also evaluated.

Finally, the resources expended on area of emphasis inspections were reviewed to determine if they were sufficient nd not excessive.

Area of emphasis inspections appropriately focused on significant generic safety issues. GAT inspections and safety issue inspections resulted in the identification of significant issues and precipitated improved industry j

performance. All regions effectively identified, evaluated, and communicated significant inspection findings that had possible generic implications throughout the NRC.

Regional and NRR managers indicated that the current level of effort expended on area of emphasis inspections was appropriate.

Resource expenditures for area of emphasis inspections for FY 92 were only 10 percent of the total inspection effort as compared to the 26 percent estimated.

9 3.1 IDENTIFICATION OF SIGNIFICANT SAFETY ISSUES This element solicited information for determining those generic issues that the staff believed to be most significant. NRR solicited information from the regions and reviewed generic communications, significant events, events that precipitated AITs, precursor data, and the Generic Issue Management Control System update developed by the Office of Nuclear Regulatory Research (RES).

NRR also solicited informal input in ussions with representatives of RES, the Office for Analysis and Evaluation ut Operational Data (AE00), and the Office of Enforcement (0E).

From this input, a determination was made of the most significant generic concerns. The three most significant concerns were safety system reliability, loss of offsite power, and significant safety related electrical equipment failures or equipment deficiencies. The reliability of equipment vital to safe plant operation was identified as a concern by the regions, RES, and OE.

Loss of offsite power (LOOP) was considered to be a significant generic concern because there have been 18 full or partial LOOP events since June 1989. Electrical equipment failures or equipment deficiencies were considered to be a generic concern because of the significant number of failures, including emergency diesel generator failures, degraded electrical bus conditions, and electrical equipment protective feature failures.

There were several other areas identified during the NRR review that may warrant further NRC evaluation as significant generic issues based on common concerns expressed by different organizations within the NRC or the frequency of event recurrence.

These included:

Reactor core thermal-hydraulic response and cladding damage.

Examples included unexpected fuel cladding failures at pressurized water reactors (PWR) and power oscillations during startup of a boiling water reactor (BWR) identified as a concern by the regions.

Degraded shutdown cooling events.

Steam generator degradation, such as tube leaks and ruptures, plug failures, surface and subsurface cracks in girth welds, and failure to properly hard roll tubes into steam generator tube sheets.

Balance of plant equipment failures have challenged safe plant operation, such as the effect of control air reliability on the ability of safety related equipment to perform its intended function identified as a concern by the regions.

Review of issues identified by the regions as requiring additional emphasis, i

found them to be consistent with concerns and issues expressed by other NRC organizations.

Overall, the regions appropriately focused on safety significant generic issues.

Overall rating:

SATISFACTORY.

e 10 3.2 INSPECTION PROGRAM FOCUS ON THE SAFETY SIGNIFICANT GENERIC ISf0ES This element focused on evaluating whether current area of emphasis inspections address those generic issues believed to be the most safety significant as identified in Element 3.1.

In addition, the ins;,ection effort expended in the area of emphasis inspection program was evaluated to determine if it was appropriate.

GAT inspections currently being conducted are electrical dist*ibution system functional (EDSFI) and service water systems operational perfarmance (SWOPI) team inspections. Also a pilot team inspection was conducted in each region to determine whether GATS should be conducted on shutdown ris c.

These GAT inspections focused on significant generic issues as identifi ed in Element 3.1.

The safety issues inspections being conducted using temporary instructions (TI) generally fall into the broad areas identified in Element 3.1 as generic issues.

Active tis are listed in Appendix II.

Safety related equipment performance has been the focus of several tis such as those on the performance of safety-related check valves, and inservice test program req.irements.

Other safety issue inspections have focused on emerging issues including shutdown risk and BWR power oscillations.

The inspection program allocation in FY 92 for area of emphasi: inspections was 26 percent of the total inspection program budget. Only 10 percent was actually expended.

Senior regional management indicated th.at ihe current level of effort expended in the area of emphasis program was alpropriate.

This suggests that a reduction in the area of emphasis inspect 1an effort allocation would not significantly impact the ability of the pi agram to identify or follow up safety significant issues.

Overall rating:

SATISFACTORY.

3.3 COMMUNICATION OF INSPECTION FINDINGS ACROSS THE REGION AND TO HEADQUARTERS, AS APPROPRIATE This element evaluated how effectively significant findings or is sues were communicated within regions and with NRC headquarters. The evalu stion was focused on determining whether significant issues or findings, with generic implications, were appropriately communicated to other sites withi1 a region, to other regions, and to NRC headquarters staff.

Performance in this area was found to be a strength.

Implementatio.' of the inspection program identified significant issues, follow up inspections were performed, and the regions prepared draft information notices and su)mitted them to headquarters.

The regions initiated 30 draft information notices during FY 92.

In tddition to information notices, most regions summarized significant inspectiot findings and provided them to the inspection staff using technical issles summaries or other vehicles. The draft information notices or technic.1

O 11 issues summaries were of good quality, technically correct, and covered safety significant issues of potential generic concern.

Each region conducted a morning status meeting, usually with NRR Projects participation and discussed recently identified significant issues. This provided a good mechanism for communicating issues to NRC headquarters staff in a timely and effective manner. Discussions of significant issues were also conducted during daily senior regional management meetings. The focus o7 these meetings was to identify significant generic issues, determine immediate actions if necessary, and direct reactive inspection resources as appropriate, using insights from different organizational levels.

Overall rating:

SIGNIFICANT STRENGTH.

3.4 GENERIC AREA TEAM (GAT) INSPECTIONS The effectiveness of GATS was evaluated to determine whether they resulted in the identification of significant issues.

The program was then assessed to determine if GATS that identified few findings initially were redirected or cancelled.

The EDSFIs and SW0PIs provide significant insights into the ability of these systems to perform their intended safety functions.

Significant findings identified during EDSFIs included:

1) inadequate undervoltage relay setpoints for degraded grid conditions, 2) inadequate interrupting capacity of fault protection devices, 3) improper coordination of fault protection devices,

4) inadequate analysis of emergency diesel generator capacity to power safety-related loads during postulated accidents, and 5) deficiencies in emergency diesel generator mechanical interfaces (air start systems, fuel oil storage, emergency diesel generator room heating and cooling systems).

In addition, the five completed SWOPIs identified significant issues.

Findings included:

1) single failures of some active components were not properly addressed in accident analyses, 2) failure to provide assurance of adequate flow to emergency core cooling systein pump room coolers, 3) failure to resolve identified valve hammering problems, 4) failure to incorporate some valves performing safety functions into the inservice testing program, and

5) nroblems with heat transfer testing programs used to detect degraded heat' exchanger performance.

One pilot team inspection was conducted in each region on shutdown risk.

Based on the results of these pilot inspections and further technical review, the staff is considering incorporating inspection guidance on shutdown risk into the inspection program.

Overall, GATS were properly focused on significant generic issues.

GATS for electrical distribution systems will continue based on the significance of the findings, the high conditional prcbability (precursors) associated with LOOP and electrical equipment failures, and the recurring events related to the electrical distribution system performance and reliability.

Service water system GATS will continue at the current level of effort to provide additional

12 information on the scope of the problems already identified. Routine regional initiative inspections of shutdown risk and reliable decay heat removal appear adequate to identify significant concerns in this area for timely resolution.

Overall rating: SATISFACTORY.

4.

INSPECTION PROGRAM MANAGEMENT Management of the inspection program was rated: Satisfactory.

This area evaluated the regions' effectiveness at incorporating lessons learned and experience gained through inspections to improve program implementation; the implementation and quality of management oversight of inspector activities; the adequacy of communications to support inspection program implementation; and the adequacy of inspector staffing, training, and qualifications.

Overall, the inspection program was well managed with only one major weakness noted.

Requirements governing regional management oversight of inspectors were not implemented consistently. Several regions made concerted efforts to meet oversight requirements and to provide meaningful and effective feedback to their inspectors. However, in some regions managers did not achieve program expectations for frequency and duration of oversight visits, quality of activities performed by managers, and quality of feedback provided to inspectors regarding their on-the-job performance.

4.1 INSPECTION PROGRAM FEEDBACK This element assessed how effectively the regions incorporated lessons learned

)

into program enhancements and how well the regions were integrated with headquarters and each other to share inspection insights and program i

recommendations.

The regions identified lessons learned as a result of events and inspection findings, and provided feedback to headquarters and to other regions. The regions assisted NRR in developing major inspection program modifications and routine inspection procedure changes.

They provided a strong contribution to

{

the development of the revised core procedure for engineering and technical support inspections.

The regions used several effective mechanisms to promulgate insights and

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feedback on the inspection program. One region used Technical Issue Summaries i

to provide information to NRR and other regions on technical issues with generic applicability that did not reach the threshold for issuance of an Information Notice. Another region issued Inspection Findings and Inspection Guidance to share insights, highlight methods of issue identification, and to provide feedback on the implementation of the inspection program. This region

13 also conducted weekly inspection finding debrief meetings, attended by all technical divisions.

Overall Rating: SATISFACTORY.

4.2 INSPECTOR OVERSIGHT This element evaluated the performance and effectiveness of required oversight activities for regional section chiefs, branch chiefs, and senior managers.

Also, the regions' performance in implementing program requirements governing the conduct of objectivity inspections was assessed.

Some regions and some individual managers made concerted efforts to meet oversight requirements and to provide meaningful and effective feedback to inspectors following observation of their activities.

In one region, a comprehensive regional procedure provided a detailed site visit checklist that assisted managers in appropriately focusing their onsite activities.

However, in general, requirements governing regional management oversight of inspectors were not being implemented consistently. Many managers did not achieve program expectations for frequency and duration of oversight visits, quality of activities performed by managers, and feedback provided to inspectors regarding their on the job performance.

Management oversight visits by section chiefs and branch chiefs varied most l

with respect to the frequency and duration when compared to program requirements.

In most cases, a reduced duration was attributed to the administrative workload in the region, and to the adverse impact of three days onsite (as required by NRC Inspection Manual Chapter 0102, "NRR Policy for Management Oversight of NRC Activities Conducted at Reactor Facilities") on the continuity of regional operations, particularly for branch chiefs. Most branch chiefs and section chiefs stated that the frequency and duration requirements were too extensive and placed an additional burden on licensees, particularly in the smaller regions.

Above the branch chief level, division directors and their deputies generally conducted oversight visits when needed, and initiated corrective actions for identified deficiencies.

The focus on observation of inspector activities varied. Most visits included observation of inspector activities, plant walkdowns, and discussions with licensee management and control room staff. However, a large number of cases were identified where managers focused their onsite efforts on reviewing licensee activities at the expense of activities associated with the review of inspector performance. At one site, management had not attended an exit meeting in the previous year.

In several cases, inspectors felt that management did not provide adequate feedback regarding their inspection activities and performance. When meaningful feedback was received, oversight visits were generally viewed positively.

As required, most oversight visits included discussions with licensee management where comments regarding NRC impacts on plant operations were

14 solicited. However, in some instances NRC managers were unaware of the requirement to solicit feedback on the effects of NRC programs on licensee operations.

As an aid to ensuring they maintain a broad perspective, resident inspectors are required to spend at least one week offsite per year performing inspection activities at another site.

In some regions, the requirements were not fully met or the inspections consisted of brief familiarization visits to backup sites rather than participation in inspection activities.

Overall Rating: NEEDS IMPROVEMENT.

4.3 COMMUNICATIONS This element evaluated the adequacy of communications between the resident and regional inspection staffs, headquarters, licensees, the general public, and the media.

Communications within and between regions facilitated effective implementation of the inspection program. All regions established mechanisms for communicating technical information, policies, and procedures to regional personnel.

Some of these mechanisms included periodic regional meetings of resident inspectors, daily telephone calls with resident inspectors, and issuance of divisional guidance to inspection staffs. As a result of effective communications, managers and staff had thorough knowledge of NRR and regional policies, current technical issues, and inspection program guidance.

Each region conducted morning planning meetings.

In some regions, all technical divisions participated in these meetings. The meetings were concise, well-managed, and focused on the most safety significant issues.

However, in other regions, morning meetings consisted largely of lengthy reviews of plant status, regardless of event / issue significance, and were attended only by the projects divisions.

Communications with licensees were found to be effective. Methods included management meetings, inspection exit interviews, periodic SALP meetings, and frequent resident inspector meetings.

Also, communications with the public and the media were found to be effective, and included periodic, usually quarterly, meetings with the news media, as well as public SALP meetings.

Overall Rating: SATISFACTORY.

s 4.4 STAFFING This element evaluated whether policies for resident staffing, including "N+1," were being implemented and evaluated the adequacy of regional staffing to support the inspection program.

15 The regions were appropriately staffed to implement the inspection program.

Regional Division of Reactor Safety (DRS) staffs were found to be adequate to conduct core and area of emphasis inspections and to respond to emerging issues. When necessary, the regions aggressively obtained support from other regions, headquarters, and contractors to supplement inhouse expertise.

Nationally, resident inspector staffing levels were found to be acceptable.

The N+1 staffing policy was either fully implemented or exceptions had been requested and approved. Keeping the resident inspector pipeline full of qualified individuals posed a continuing challenge to regional management.

The difficulty of meeting this challenge was increased by NRC limits on overhiring.

Frequent resident inspection staff changes created additional management challenges.

In several regions, both the senior resident and resident inspector were transferred within the period of a few weeks.

While in each of these cases management had little contiol, they impacted the ability of section chiefs to maintain a corporate history of licensee activities and performance.

The responsibilities of GG-14 project engineers within the Division of Reactor Projects (DRP) differed between the regions. One region assigned project engineers to serve as technical assistants to branch chiefs.

In this region, each section was assigned a reactor engineer, who was usually an inspector-in-training. This organizational structure provided little inspection support to the resident inspection staff. Other regions assigned experienced, GG-14 inspectors or engineers (some with DRS experience, others with resident inspector experience) to each section. This organizational structure allowed the use of experienced personnel to assist the resident inspection staff in resolving emergent issues, following up significant inspection findings, and assisting the section chief and appeared to be more efficient.

Overall Rating:

SATISFACTORY.

4.5 TRAINING AND QUALIFICATION The adequacy of inspector qualifications, training, and professional development were evaluated.

The regions ensured that the requirements for initial inspector qualifications established in IMC 1245, " Inspector Qualifications," were achieved and used customized qualification journals to aid in the qualification process.

Section chiefs established qualification goals, monitored their timely completion, and ensured that on-the-job training was conducted effectively.

The NRC Technical Training Center courses that are required for qualification were viewed as excellent by the qualifying inspectors.

Beyond the completion of initial qualification, training availability and execution were mixed.

The regions provided various training opportunities including technical writing courses for inspectors, engineers, and managers and specialized health physics training. This training was useful and well received. Several cases were identified where inspectors did not meet their periodic refresher training requirements.

In most cases the training was not

16 taken because of competing high priority assignments. Subsequent to the assessment, regions took action to schedule the refresher training.

In one region, training plans were prepared for all employees and integrated to determina regional priorities.

Overall Rating: SATISFACTORY.

5.

INSPECTION PROGRAM PLANNING Inspection program planning was rated: Needs Improvement.

This area evaluated the overall effectiveness of the regions in planning inspection activities at operating reactors. NRR reviewed regional efforts to ensure that required inspection activities were planned; that scheduling of NRC major inspection and non-inspection activities were coordinated with licensee and third party activities on site; and inspections were announced in accordance with the NRC policy intended to minimize the regulatory impact on licensees.

In addition, this area evaluated whether PPRs were executed by the regions to identify trends in licensee performance and adjust inspection resources accordingly.

Implementation of the Master Inspection Planning System (MIPS) was adequate, but varied significantly among regions.

PPRs were conducted in accordance with the requirements of IMC 2515 and generally resulted in resource adjustments at individual plants based on licensee performance.

However, because the PPR and other planning processes focused on specific plants without a more integrated look at inspection resource allocation versus plant performance across the region, the regions were less effective at directing or redirecting regional initiative and reactive inspections from plants with better performance to plants with poorer performance. As a result, inspection effort applied was inconsistent with licensee performance.

5.1 MASTER INSPECTION PLAN This element evaluated whether the regions developed and maintained a master inspection plan for each site, coordinated the scheduling of headquarters and regional activities with major activities planned by licensees, and adhered to i

the policy of announcing inspections.

The regions developed and maintained inspection plans in the MIPS and ensured their completion.

Regions used the inspection plans effectively to coordinate team inspections and other major activities to minimize the impact of these activities on licensees.

However, in some of the regions, a few of the inspection plans were found to be deficient in that several large team inspections were not scheduled, TI status was incomplete, and some resident inspector offices did not have current copies of their site's inspection plan.

17 The regions' ability to use MIPS as a tool for planning inspection activities varied. Most of the regions had difficulty in using MIPS, and regional personnel stated that the system did not permit on line scheduling and was not user friendly. The MIPS appeared to be particularly weak in its ability to accommodate frequent schedule changes necessary to support a dynamic inspection program. However, in some cases these difficulties in using MIPS resulted from a lack of staff training and familiarity. As a result of close management involvement, one region achieved considerable success in implementing MIPS.

In this region, inspection plans were complete and managers required the inspection staff to notify the appropriate section chief if inspection activities were expected to significantly exceed the pre-planned inspection effort. As a result, inspection plans were accomplished as planned.

The regional implementation of the announced inspection policy was reviewed against the requirements of IMC 0300, " Announced and Unannounced Inspections."

In response to the Regulatory Impact Survey, the policy was revised on May 29, 1992 to state that most routine inspections should be announced 1 month in advance and team inspections should be announced 2 or 3 months in advance. No region consistently announced inspection activities in accordance with this program guidance.

Routine inspections were sometimes announced less than one week before the start of the inspection and team inspections were often announced within one week of the inspection.

Overall Rating: NEEDS IMPROVEMENT.

5.2 PLANT PERFORMANCE REVIEW This element evaluated the effectiveness of the regions' use of the PPR process. Specific review areas included:

adequacy of plant performance data reviewed at PPR meetings; whether inspection effort allocation decisions considered SALP ratings, insights from the Senior Management Meeting process, or performance indicators; the quality of PPR results; and the overall effectiveness of the PPR process in incorporating insights from other sources.

The regions conducted PPR meetings in accordance with the requirements of IMC 2515.

The meetings were attended by appropriate levels of regional management and staff.

Senior resident inspectors and NRR representatives usually participated in person or by telephone.

The regions prepared for these meetings by compiling data packages focused on licensee performance. These packages typically included a summary of plant operations since the last PPR meeting, recent inspection program activities and findings, SALP ratings and trends, resident inspector concerns, evaluation 1

of key performance indicators and recommended changes to the inspection plan.

f I

18 PPRs provided timely evaluation of trends in performance of specific licensees and resulted in adjustments in planned inspection activities to follow up events and potential issues. However, the PPR and other planning processes focused on specific plants without providing a more integrated look at inspection resource allocation versus plant performance across the region.

This resulted in the regions being less effective at directing or redirecting regional initiative and reactive inspections from plants with better performance to plants with poorer performance. As a result, a lack of correlation between licensee performance and inspection effort was found to exist in several instances.

Overall Rating: SATISFACTORY.

5.3 OPEN ITEM LIST This element evaluated whether regions had implemented a formal process for managing open items resulting from inspections, whether open item lists were properly maintained, and whether open item closecut was properly managed.

Generally, the regions communicated strong and effective policies for the use and timely resolution of open items. All regions used open items appropriately to identify items that required specific NRC follow up inspection activities or licensee actions. However, the identification and closeout of open items that were not categorized as violations varied between the regions.

For example, unresolved items (URI) are generally reserved for open items that were potential violations of NRC requirements. Although most regions used URIs accordingly, one region characterized most items as URIs and left them open sometimes in excess of a year.

The current policy for tracking open items does not require the tracking of non-cited violations (NCV). As a result, regional inspection staffs and regional management generally relied on corporate memories to ensure that issues resulting in NCVs were not the result of less than adequate licensee corrective actions.

In light of the number of instances that were identified where the senior resident inspector, resident inspector, and regional managers were replaced within a short period, this area requires close management attention given current direction to not require a tracking system.

Overall Rating:

SATISFACTORY.

6.

INSPECTION PROGRAM PERFORMANCE i

Inspection program performance was rated: Satisfactory.

This area evaluated the performance of inspection program activities to determine whether procedures were accomplished in accordance with program requirements and by qualified staff.

It also evaluated whether the requirements regarding site coverage during resident staff absences were

19 accomplished and whether the regions appropriately responded to events. A one-time review of regional implementation of the allegation management program was performed.

The regions conducted inspection activities in accordance with program

'i requirements and identified issues that were significant to plant safety.

Most inspections were performance-based and resulted in the identification of appropriate findings. However, in seve~ral instances in all regions, maintenance and surveillance observations by resident inspectors lacked thoroughness or substance.

i The regions emphasized onsite inspection of licensee activities and matched the capabilities of inspectors to required inspection tasks.

Regional success in achieving the desired onsite inspection effort for inspectors varied, with two regions consistently exceeding program goals and the other three regions falling short of program goals.

l Event follow up activities in all regions were considered to be a strength, i

They were timely, focused on safety, and were of high quality. The safety significance of events was determined shortly after events occurred.

Regions responded through the use of resident inspector onsite follow up, AITs, and other regional reactive inspection efforts.

l, The regions implemented the allegations management program in accordance with program requirements. Allegation review activities were timely, independent, i

and well documented. The Regions effectively corrected previously identified minor weaknesses.

j 6.1 INSPECTION PROCEDURES ACCOMPLISHED This element evaluated the regions' accomplishment of required inspection procedures. Specific review areas included:

safety significance of inspection findings; method of identification of significant findings; performance-based nature of the inspections; accomplishment of inspection procedure requirements; use of probabilistic risk assessment (PRA) in inspections; inspection procedure time estimates; and accomplishment of tis.

s The regions placed a strong emphasis on ensuring that core program inspections

{

and required area-of-emphasis inspections were completed at each site.

Inspections met the intent of procedural guidance and in most cases were performance-based.

Method of Identification Those inspections providing inspectors with the best opportunity to focus in-depth in a specific area yielded the most safety significant findings. These j

included well planned team inspections, independent resident inspection 1

activities, and detailed event follow up inspection activities. Team i

inspections appeared to be effective.

Inspectors were permitted to adequately prepare for the inspection, and inspection plans received management review i

and input. Also, inspection teams provided a focused, multi-disciplinary i

P g

y 3

s w.

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20 review of licensee performance by NRC and contractor experts.

Inspections conducted by groups of inspectors resulted in a greater number of findings than those conducted by individual inspectors due to the interactions between team members.

Conversely, routine inspection activities by individual inspectors conducting week-long inspections were found to be less likely to identify safety significant findings because a significant part of the inspection week was lost to travel, badging, and inspection exit preparation. However, the success of all inspections, including team inspections, was highly dependent on inspector capability and performance.

i Performance-Based Inspections In general, inspection activities in all regions were performance-based and focused on the review of safety significant issues. A few inspections, however, were implemented in a programmatic manner and yielded few safety significant findings.

For example, one region conducted an in-depth review of the effectiveness of Inspection Procedure (IP) 40500, " Evaluation of Licensee Self-Assessment Capability." The analysis indicated that programmatic implementation of the procedure by inspectors who sometimes did not have the correct knowledge and skills reduced the effectiveness of the inspection.

In addition, a case was identified where inspectors conducted IP 42700, " Plant Procedures" to review the adequacy of licensee procedures, but did not conduct walkdowns or in-plant verifications.

Recuirements Inspections were generally accomplished in accordance with Inspection Manual Chapter (IMC) requirements. However, in all regions there were examples where maintenance and surveillance observations by resident inspectors appeared to lack thoroughness or substance. Many resident inspection reports provided little analysis of licensee maintenance activities observed.

In addition, inspectors sometimes observed activities of little importance.

Core procedures for observation of maintenance and surveillance activities will be changed to emphasize the quality of the maintenance observations versus the

)

quantity of observations.

1 Use of Probabilistic Risk Assessment (PRA)

The regions' use of PRA insights in conducting inspections was evaluated.

PRA I

insights were used in planning and conducting team inspections.

Generally, resident and region-based inspectors periodically used Risk-Based Inspection Guides (RIG) in selecting systems for maintenance observations, surveillance observations, design modification reviews and equipment out-of-service reviews. However, inspectors in two regions were unfamiliar with RIGS and did not use them. Most inspectors were trained on the use of PRA insights.

Regions that did not utilize RIGS were advised to incorporate them in j

inspection activities where appropriate.

21 Inspection Procedure Time Estimates The estimates for completion of core inspection procedures established in IMC 2515 were reviewed against historical expenditures. The hours expended to complete core inspection procedures varied widely from those estimated in the inspection manual.

For example, the majority of all reactor sites received more inspection against IP 71707, " Operation Safety Verification" than estimated. Some reactor facilities received more than twice the estimated hours. Many sites received more than double the estimated hours against IP 62703, " Maintenance Observation." EP exercise observations required about twice the estimated hours of IP 82301, " Evaluation of Exercises for Power Reactors." An insufficient number of hours were allotted for IP 40500,

" Evaluation of Licensee Self-Assessment Capability," to accomplish the objectives of this procedure.

See Element 1.4 of this report for additional information on inspection procedure time estimates.

Accomolishment of Temocrary Instructions (TI)

A detailed review was conducted of the actions taken to complete tis pertaining to loss of decay heat removal, performance of safety related check valves, reliable decay heat removal during outages and verification of plant records. The results of inspections were forwarded to NRR as requested.

These tis were completed on or ahead of scheduled completion dates.

A sample of inspection reports that closed out each of the tis were reviewed.

Inspections thoroughly and appropriately addressed all required areas.

Overall Rating:

SATISFACTORY.

t 6.2 INSPECTOR UTILIZATION This element evaluated the effectiveness and consistency of inspector utilization. Specific review areas included correct discipline and training, contractor and headquarters support, inspection preparation and documentation, and use of overtime.

The regions matched inspector capability to required inspection tasks.

When necessary, the regions used support from other regions, headquarters and contract personnel. All regions ensured that qualified and experienced team leaders led regional inspection teams.

Regulatory Information Tracking System (RITS) data were reviewed to evaluate the effort being devoted by inspectors to preparation, documentation, and direct inspection. Since the RITS system does not distinguish between preparation and documentation, separate analyses could not be performed to evaluate the percentage of inspector hours devoted to each area.

Interviews indicated that region-based inspectors in most regions devoted minimal time preparing for inspections.

For inspectors performing inspections in familiar areas, this was sufficient. However, in some cases, the lack of preparation time may have resulted in overly programmatic inspections and the low number of significant issues identified by region-based inspectors.

i 9

22 National averages compared favorably with NRR guidelines. However, some significant regional variations existed. One region had low direct inspection from senior resident, resident, and Division of Radiation Safety and Safeguards (DRSS) inspectors. Another region had low direct inspection from all region-based inspectors.

Finally, one region had low direct inspection from resident inspectors due to time lost to train new residents hired in response to inspection staff turnover. Three regions had high direct inspection effort from the resident inspection staff.

Overall Rating: NEEDS IMPROVEMENT.

6.3 SITE COVERAGE This element evaluated the effectiveness of the regions' implementation of site coverage requirements. Specific review areas included backshift coverage and site coverage when the resident inspection staff was absent.

All regions placed strong emphasis on performing required backshift inspections and met the program goal stated in IMC 2515 that 10 percent of resident inspection effort be devoted to backshift. Although inspectors rarely identified significant issues during backshift inspection, they appear warranted because of their value in deterring improper licensee operations during the backshift.

Since some sites were found to have minimal activity during the backshift, the amount of inspection required to achieve the desired safety objectives may be less than prescribed by IMC 2515. The backshift coverage program goal requires further evaluation.

The regions complied with the requirements of IMC 2515 for coverage of reactor sites during resident absences. However, a few resident inspectors were not badged at their backup sites. One region did not designate the backup resident in writing, and in other regions a small number of resident inspectors did not know their backup site assignments.

Although these deficiencies existed, the underlying goal of ensuring that qualified inspectors were available to respond to sites when needed was not compromised because qualified inspectors and managers were available from the regional offices.

Overall Rating: SATISFACTORY.

6.4 EVENT FOLLOW UP This element evaluated the effectiveness of the regions' event follow up activities. Specific review areas included the accuracy of regional determinations of event safety significance, appropriate response to events, and communication of results to NRC headquarters, other regions, licensees, the public, and the media.

i

4 23 Event follow up activities were a significant strength in all regions. 1.%

regions determined the safety significance of events shortly after they occurred. A resident inspector, a backup resident, or a region-based inspector always responded to the site in the event of a significant operational occurrence. The regions conducted reactive follow up inspections that included AITs, regional reactive teams, and regional reactive individual I

inspections.

Follow up inspections provided accurate insights regarding the j

root causes of problems.

Issues identified were properly investigated and resolved.

Horning reports issued by the regions were timely and accurate.

They contained sufficient technical and operational detail to permit accurate event assessment. The regions participated in the Operating Reactors Events Briefings and provided valuable insights on issues and problems.

Overall Rating: SIGNIFICANT STRENGTH.

6.5 ALLEGATION FOLLOW UP Within this element, the effectiveness of the regions' implementation of the allegation program was reviewed. Specific review areas included the timeliness of accomplishing program requirements, completeness of allegation management files, and effectiveness in maintaining alleger anonymity.

Regional implementation of the allegations program was reviewed against the requirements of Management Directive (MD) 8.8, " Management of Allegations." A sample of open and closed allegation files were reviewed.

The implementation of the allegation program was effective and in accordance with MD 8.8.

Allegation follow up inspections were timely, thorough, and reflected independent verification to resolve concerns. Allegation management files were complete and clearly documented the staff's response to allegers' i

concerns. The regions maintab.ed alleger anonymity.

Previously identified weaknesses, such as not performing timely updates to the I

i Allegations Management System, not referring allegations with issues of j

wrongdoing to the NRC Office of Investigations within fifteen days, and including references to allegations in inspection reports, were corrected.

The assessments identified allegation letters that were received at NRC headquarters that had been erroneously placed into NUDOCS, but were withdrawn

{

before they were placed in the public document room.

This issue was referred l

to the NRC allegation program manager for future investigation and corrective g

action.

Overall Rating:

SATISFACTORY.

1 c

24 7.

INSPECTION PROGRAM DOCUMENTATION Inspection program documentation was rated:

Satisfactory.

This area evaluated the overall quality of inspection program documentation to assess whether inspection program requirements and goals were achieved.

Inspection reports reflected an appropriate focus on public health and safety, and they contained clear and concise safety significant findings that were well supported by facts and references.

Inspection report forwarding letters provided clear messages to licensees regarding the NRC's perception of the significance of identified concerns.

Few inspection reports met all of the inspection program format requirements of IMC 0610, " Inspection Reports." These discrepancies were of minor significance. Nationally, many inspection reports were issued that exceeded the timeline!s goals of IMC 0610.

Individual regions initiated corrective action for findings identified.

1 7.1 INSPECTION REPORT CONTENT This element assessed the quality of inspection report content, including safety focus, root cause analysis, and bases for findings.

Approximately 100 inspection reports per region were reviewed. Although most inspection reports documented the root causes of problems and discussed the supporting bases, rationale, and references for the findings, a few minor weaknesses were identified. One general weakness was that many inspection reports did not clearly describe the inspection scope nor did they summarize conclusions regarding the adequacy, strengths, or weaknesses of the licensee's performance or programs. Also, several inspection reports included lengthy descriptions of licensee programs and activities with little evaluation by the inspector.

Despite the weaknesses, inspection reports identified and addressed significant safety issues, and reflected quality technical review and analysis of licensee activities.

Overall Rating: SATISFACTORY.

7.2 INSPECTION REPORT FORMAT This element evaluated inspection report format and timeliness.

Specific review areas included conformance to IMC 0610 format requirements, co'nsistency of the use of follow up items, and conformance to IMC 0610 timeliness requirements.

i Most inspection reports met the basic format requirements and documented violations, deviations, and follow up items in a consistent manner. However, several inspection reports did not indicate whether inspections were announced

e I

25 or unannounced and several inspection reports did not indicate the extent that the licensee expressed agreement or disagreement on inspection findings.

Inspection reports were also reviewed for timeliness.

IMC 0610 established a timeliness goal of 21 calendar days for issuing inspection reports after the inspection was completed (30 calendar days for major team inspections), but required that reports ta dispatched within 30 calendar days after the inspection was completea (45 days for major team inspections).

Nationally, on average, inspection reports were issued beyond timeliness goals, but within timeliness requirements. However, there were examples where individual inspection reports were issued in excess of timeliness requirements. This was particularly true for DR$ reports, that were often detailed and involved complex subject matter.

Overall Rating:

NEEDS IMPROVEMENT.

t

4 i

APPENDIX I ASSESSMENT TEAM ACTIVITIES Region I office visit:

March 15 to 19, 1993 Reactor site visits:

March 10, 1993 - Beaver Valley, Indian Point 2 Team leader:

A. T. Gody, Acting Director PMAS/NRR Team members:

J. A. Calvo, Assistant Director for Region I Reactors; M. R. Johnson, ILPB/NRR; V. M. McCree, OED0; D. L. Gamberoni, ILPB/NRR; M. C. Shannon, ILPB/NRR Region II office visit:

December 14 to 18, 1992 Reactor site visits:

December 11, 1992 - Robinson, Sequoyah Team leader:

A. T. Gody, Acting Director PMAS/NRR Team members:

G. C. Lainas, Assistant Director for Region II Reactors; M. R. Johnson, ILPB/NRR; L. R. Plisco, OED0; D. L. Gamberoni, ILPB/NRR; D. K. Allsopp, ILPB/NRR Reoion III office visit:

January 11 to 15, 1993 Reettor site visits:

January 8,1993 - Palisades, Point Beach Team leader:

A. T. Gody, Acting Director PMAS/NRR Team aembers:

T. L. Kind, Acting Assistant Director for Region III Reactors; W. H. Bateman, OED0; M. R. Johnson, ILPB/NRR; M. J. Davis, RPEB/NRR; D. L. Gamberoni, ILPB/NRR; G. Y. Suh, ILPB/NRR Region IV office visit:

April 19 to 23, 1993 Reactor site visits:

April 7 to 8, 1993 - Cooper, Waterford Team leader:

A. T. Gody, Acting Director PMAS/NRR Team members:

M. R. Johnson, ILPB/NRR; D. L. Gamberoni, ILPB/NRR; M. C. Shannon, ILPB/NRR; D. J. Sullivan, ILPB/NRR Region V office visit:

February 8 to 11, 1993 Reactor site visits:

February 5,1993 - Diablo Canyon, Palo Verde Team leader:

A. T. Gody, Acting Director PMAS/NRR Team members:

M. J. Virgilio, Assistant Director for Region IV/V Reactors; M. R. Johnson, ILPB/NRR; D. L. Gamberoni, ILPB/NRR; W. H. Lovelace, ILPB/NRR; M. C. Shannon, ILPB/NRR

(

APPENDIX II I

Currently Active 2515 Inspection Program Temporary Instructions 2515/109,

" Inspection Requirements for Generic Letter 89-10, Safety-Related Motor-0perated Valve Testing and Surveillance" 2515/110,

" Performance of Safety-Related Check Valves" 2515/111,

" Electrical Distribution System Follow up Inspection" 2515/112,

" Licensee Evaluations of Changes to the Environs Around Licensed Reactor Facilities" 2515/113,

" Reliable Decay Heat Removal During Outages" 2515/114,

" Inspection Requirements for Seneric Letter 89-04, i

Acceptable Inservice Testing Programs" 2515/115,

" Verification of Plant Records" 2515/116,

" Access Authorization" 2515/117,

" Licensed Operator Requalification Program Evaluation"-

2515/118,

" Service Water System Operationa' Performance Inspection (SWOPI) - GAT" 2515/119,

" Water Level Instrumentation Errors During and After Depressurization Transients (GL-92-041)"

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