ML20057C051
| ML20057C051 | |
| Person / Time | |
|---|---|
| Issue date: | 09/20/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 9309270009 | |
| Download: ML20057C051 (86) | |
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UNITED STATES OF AMERICA 1
NUCLEAR. REGULATORY COMMIS SION i
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BRIEFING ON NRC REACTOR INSPECTION PROGRAM ASSESSMENT AND PLANNED IMPROVEMENTS Location:
RoCKVILLE, MARYLAND bd(6.
SEPTEMBER 20, 1993 t
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1 NEALR.GROSSANDC0.,INC.
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1323 Rhode Island Avenue, Northwest l
Washington, D.C.
20005.
l (202) 234-4433 i
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l DISCLAIMER i
This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on 1
September 20. 1993, in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding 'as the result of, or c$ dressed to, any statement or argument contained herein, except as the Commission may authorize.
e e
NEAL R. GROS $
CoUtf Rfpottttt$ AND TRANSCRftf8t$
1323 GMo06 ISLAMO AVfNUt, N.W.
(202) 234-4433 WMMIN0foM, DL 20005 (202) 232-6600
1 UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION BRIEFING ON NRC REACTOR INSPECTION PROGRAM ASSESSMENT AND PLANNED IMPROVEMENTS PUBLIC MEETING l
l Nuclear Regulatory Commission One White Flint North Rockville, Maryland
)
Monday, September 20, 1993 i
I l
l The Commission met in open
- session, l
l pursuant to
- notice, at 3:00 p.m.,
Ivan
- Selin, Chairman, presiding.
COMMISSIONERS PRESENT:
IVAN SELIN, Chairman of the Commission KENNETH C.
ROGERS, Commissioner FORREST J.
REMICK, Commissioner E.
GAIL de PLANQUE, Commissioner NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W.
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STAFF SEATED AT THE COMMISSION TABLE:
f i
i WILLIAM C.
PARLER, General Counsel i
ANDREW' BATES, Office of the General Counsel I
JAMES TAYLOR, Executive Director for Operations THOMAS MURLEY, Director, NRR STEWART EBNETER, Region II Administrator WILLIAM RUSSELL, Associate Director for Inspections 1
and Technology Assessment, NRR JAMES MILHOAN, Region IV Administrator ANTHONY GODY, SR.,
Chief, Inspections and Licensing Policy Branch, NRR 1
HUBERT MILLER, Deputy Administrator, Region III o
e i
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P-R-O-C-E-E-D-I-N-G-S 2
3:00 p.m.
3 CHAIRMAN SELIN:
Good afternoon, ladies 4
and gentlemen.
I'm particularly interested in this 5
meeting this afternoon since for a long time we've 6
been talking about how importcnt a reactor inspection 7
program is and yet we found it difficult to come up 8
with some kinds of measures to say how are we doing, l-9 how is the program doing, how does it carry out the 10 interests of the public, is it worth the money we're 11 spending on it, should we be doing more or less a 12 little bit differently.
13 over the past several years, substantial 14 revisions have been made to this inspection program.
15 The growing role of team inspections has been 16 organized.
The N+1 resident inspector program has 17 been implemented. The relation between the inspection 18 program and the recogiution that the likelihood of 19 finding problems is different at different licensees 20 depending on their experience has been growing.
So, 21 in order to evaluate the effectiveness of.this 22 program, a detailed program assessment process was 23 developed and implemented by the staff this year.
24 Today's meeting serves as a means for the 25 staff to provide the Commission with the reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WASHINGTON. O C 20005 (202) 2344433
4 1
inspection program ' assessment methodology and with l
s 2
results of the review of the program.
3 I understand that copies of the viewgraphs I
4
-are available at the entrance to the room.
1 5
Commissioners?
6 Mr. Taylor, would you proceed, please?
7 MR. TAYLOR:
Good afternoon.
With me at 8
the table is a
very strong representation for 9
inspection program.
In addition to Doctor Murley, 10 Bill Russell and Tony Gody from NRR.
We have with us
{
11 three folks from the regions, Stu Ebneter, Jim t
12 Milhoan, region administrators, and Hub Miller, Deputy l
13 Regional Administrator in Region III.
t 1
14 I would take note that the report prepared 15 by the staff on the inspection program dated August 16 25th is available at the door and I thought this was 17 a very broad sweeping and forthright view of the 18 various parts of our inspection program.
19.
With those thoughts, I'll ask Doctor 20 Murley to continue.
d 21 DOCTOR MURLEY:
Yes.
Thanks, Jim.
22 I have some background remarks before Tony 23 Gody gets into the assessment that we did..
24 The NRC inspection program is' the 25 cornerstone of our regulatory process for assuring the f
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COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W
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1 safe operation of nuclear power plants.
Because it's i
2 so important, we regularly review the program and we 3
make adjustments when we see the need.
For example, 4
going back to the mid '80s, we began to turn the focus
{,
5 of the inspection program away from strict compliance 6
orientation toward a more diagnostic focus to help us l
1 7
judge how well plants were being operated.
l t
8 Then in 1987, we changed the program to 9
issue guidelines to structure the program in three i
10 main areas. The first was the core inspection program 11 which is largely carried out by resident inspectors 12 and each plant in the country receives that core 13 program.
The second area was regional initiatives 14 which are largely event driven and, of course, vary 15 from region to region.
The third area are special i
16 area inspections.
These are team inspections at each 17 plant in the country where the staff judged that there i
18 was a safety concern.
19 For
- example, an emergency operating 20 procedures'we did a team inspection, maintenance team 21 inspection, electrical distribution functional and 22 system inspection and service water system inspection.
23 In 1989 the staff did a regulatory impact 24 survey where a number of senior management -- each of 25 the regional administrators and myself and the senior NEAL R. GROSS COURT REPORTERS Ar4D TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 W ASHINGTON, D C 20005 (202) 2344433
6-l 1
managers in NRR went on teams and we looked at 13 l
2 different sites in all five regions just to find out t
i 3
'how the regulatory program was being developed and r
4 implemented and what problems were being caused. Part 5
of it, of course, was generic communications at 6
Headquarters, but a large part had to do with the 7
inspection program and the way it was being l
8 implemented.
The results of that led us to make some 9
changes in the inspection program.
It led to the need
{
10 for controls on the number of large team inspections 11 at a given site and a given time and, perhaps more j
12 significant, it led us to conclude that more i
13 management attention was needed to the training and 14 oversight of individual inspectors.
15 In 1990 and
'91, as the Chairman 16 mentioned, we implemented the Commission's N+1 policy 17
'on resident inspectors.
.This had largely been done 18 certainly at one unit sites and several two unit J
19 sites, but we fully implemented it in 1991.
20 1992 and
'93, we undertook the SALP f
t 21 program review.
While it didn't directly affect the 22 inspection program, it's going to have ramificatione l
23 that will, we think, affect the inspection progran.
1 24 because there won't be as many SALP categories, for 25 example, and therefore there won't be the need for as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W aa2i 234.u33 wAss%oTON.Dc 20ms (202, 234.u33
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1 much inspection in'certain areas as we had-before.
-1 2
Then finally, in 1993, we did the special j
i 3
assessment that Tony Gody will talk about in just a l
4 second.
5 The basic questions of concern to the 6
Commission we understood were the following:
7 Number one, does the inspection program 8
look at the right things, and I'll. give a short 9
answer, and-that is yes.
We think the program is 10 focused on operational safety performance, as it i
11 should be.
i 12 Second question, is the inspection program 13 effective in meeting its objectives.-
That is in 14 looking at the things it looks at.
Here we get a 15 little subjective, but my answer would be yes, that it i
16 is effective if we can judge by the trends that we see
-?
'l 17' over the last several years in performance indicators I
i 18 and in the accident sequence precursor results.
But 19 we have to at the same time say that the inspection i
20 program is not the only means that affect these
-i 21 performance of licensees and plants.
We have many 22 arrows in our quiver, so to speak.
We have AITs, 23 IITs, diagnostic team inspections, operator exams, 24 vendor inspections, the whole allegation program and 25 allegation follow-up program.
So, one really has to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE. ISLAND AVENUE, N W.
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t 8
1 look-at the entire regulatory process for ensuring i
2 safety, but nonetheless the inspection program is, as 3
I said, the cornerstone of that entire regulatory 4
process.
5 The third question would be do we have the 6
right level of resources applied.
We think that in 7
the past we have, but we'also believe that we can 8
reduce the inspection resources somewhat over the next 9
few years and the plans are to do that.
10 A fourth question would be is the program 11 consistently implemented across the country. We would
{
t 12 say generally
- yes, but we recognize that.some 4l 13 improvements are needed and for sure we have to make 14 sure that we continually watch that aspect of it, both 15 the regional administrators and NRR.
16 So, with that introduction, Tony Gody will 17 talk about the assessment itself.
18 COMMISSIONER ROGERS:
Could I just raise l
19 one very brief question --
]
20 DOCTOR MURLEY:
Yes.
21 COMMISSIONER ROGERS:
on the N+1 22 program.
Is it, in fact, the case that we have N+1 23 resident inspectors at each site in the country now?
1 24 I don't believe we do.
Do we?
25 DOCTOR MURLEY:
No.
No.
No.
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9 1
COMMISSIONER ROGERS:
I thought we had --
2 MR. EBNETER:
You give us latitude too.
3 COMMISSIONER ROGERS:
Yes, we had some 4
latitude there and I think that's proper.
But when 5
you say implemented, I guess that means that we're 6
prepared to do it, but if you don't find that a 7
particular site really justifies that-with a better 8
use of resources, you would not have N+1 at the site.
9 DOCTOR MURLEY: Yes. We're actually -- as 10 you know, Commissioner, we have asked the Commission 11 for some latitude and we have received that approval.
12 COMMISSIONER ROGERS:
Yes.
13 DOCTOR MURLEY:
And we're coming down a 14 bit.
But each site, if it doesn't neet H+1, there has 15 to be a justification f rom the regional administrator 16 to me and we approve it back here.
So, it's on an 17 exception basis where they' don't do it and we look at 18 that pretty carefully, by the way.
19 COMMISSIONER ROGERS:
Right.
Thank you.
20 DOCTOR MURLEY:
Tony?
21 MR. GODY:
That exception policy was put 22 into effect December of "92 and there's currently 13 23 sites that don't have N+1.
All of those are either a 24 dual or a triple unit site.
A single unit site still 25 has to have two resident inspectors.
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COMMISSIONER REMICK:
How many sites 2
exceed the N+1 currently?
Do you happen to know that 3
number?
4 MR. GODY:
No.
5 COMMISSIONER REMICK: Certainly Watts Bar, 6
Brunswick?
7 MR. GODY:
Yes.
I don't think any of them 8
do unless it's -- Pilgrim did.
9 DOCTOR MURLEY:
Pilgrim still does, I
10 think, yes.
11 COMIIISSIONER REMICK:
Okay.
12 MR. GODY:
NRR has been doing assessments 13 of the regions' implementation of the operating i
14 reactor inspection program since 1987. As a matter of 15 fact, there's an inspection manual chapter established 16 that developed the guidance for these assessments.
17
- However, in September of
'92, because of several 18 questions asked by the Commission and the Chairman, wo 19 decided to develop a new assessment procedure, one 20 that would establish the assessment guidance and, in 21 fact, be made public through memos or a Commission 22 paper that would be Ient to the Commissioners.
23 This program that we develop is one that 24 evaluates the effectiveness of the inspection program 25 as well as the region's implementation of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON. D C. 23005 (202) 234 4433
11.
1 program.
Two primary considerations - were are we 2
looking at the appropriate areas and are we using the 3
appropriate amount of resources.
We also defined the
{
4 objectives of the inspection program and incorporated e
5 assessment guidance to ensure that we were meeting
. )
t 6
those objectives.
i 7
We developed an assessment tree and 8
assessment guidance, sent them out to the regional 9
offices for comments, received those comments and
[
10 incorporated the appropriate comments into our 11 guidance.
One thing this did was give the regions an la idea of what we were looking at and what our measures l
13 were ge4ng "o be.
14 Prior to conducting the actual assessment, i
15 we sent the region-the finalized assessment guidance, f
16 This approach differed from what we'had done in the i
17 past and the regions were able to prepare for the i
18 assessments and also conduct, several of them did, 19 self-assessments before we came on site.
As I said, f
20 we.made these available 'to the commission, the 21 assessment criteria to the Commission in a memo from i
Jim Taylor and also the results were in a final report 22 23 on the national assessments.
24 I'd like to talk a little bit about the t
25 assessment methodology.
We did look at the program NEAL R. GROSS COURT RFPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202; 234 A433 WASHINGTON. D C 20005 (202) 234-4433 I
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effectiveness and the region's implementation of the 2
program.
In the inspection program effectiveness 3
area, the overall program is divided into three areas.
4 Tom mentioned the core inspection program, regional 5
initiative and area of emphasis.
We looked into all 6
three to see if significant safety issues were being
)
7 identified before thay became self-revealing. Was the l
8 program picking out these areas?
Generally we found 9
that' it was.
Also that. inspection resources were 10 applied consistent with licensee's performance.
We 11 found some areas there where.that was not the case.
i 12 And that the focus of the program was placed on the 13 identification of generic issues.
14 The other part of the program was we 15 looked at the regional inspection program execution.
2 16 In that area we looked at management.
That was the 17 oversight of the inspectors and the program, staffing, 18 training qualification, those types of things.
We 19 looked at planning.
That was, did the planning 20 coincide with licensee performance, was the inspection 21 resource allocation did that match what the 22 licensee's performance was? And the performance, and
~
23 that was just how well the regions implemented the 24 program, and then documentation, how well we reported 25 the findings.
NEAL R. GROSS COURT REPORTER $ AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W 1232) 234 4433 WASHINGTON. O C. 20005 (202) 234 4433
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't 13 1
We also looked at the core inspection P
2 effort at good performers.
The core is the minimum
~
3 amount of inspection that's applied to all plants and '
l 4
it would be the least amount of inspection that we 5
devoted to a good performer.
We just wanted to make s
6 sure that that effort was sufficient and we found that 7
it was.
As a matter of fact, during the assessment I
8 that was one of the strengths that were identified.
9 The assessment activities, I want to r
10 discuss how the assessment was conducted and the 11 mechanics of it.
Prior to going to the region we did 12 a two week in-office documentation and data review.
13 That consisted of reviewing a
minimum of 100 14 inspection reports per region.
We looked at the i
15 licensee event reports for the previous two years, 16 recent SALP reports, inspection data and enforcement 17 history. Then we conducted a one week regional office l
18 visit where we had interviews with everyone from the 19 regional administrator down to the inspectors.
t 20 We also during these assessment visits
~
21 visited two reactor sites per assessment to gather i
i insights from the licensees on how they' viewed the l
22 h
23 implementation of the program at their facilities and l
7' 24 also any regulatory impact items that they might want 25 to discuss.
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Following the site visits and the regional l
2 office visit we had a preliminary exit that was 3
conducted by the assessment team, went back to the 4
office and did a further review of data we collected 5
an-en we had, approximately three weeks later, a 6
final exit with the Deputy Director of NRR, Frank-7 Miraglia and myself.
Went back, presented the region 8
with our findings, gave them a draft assessment 9
report, requested that they send that back to us 10 within two or three weeks and reconciled any 11 differences there were and issued a final report 12 within about eight weeks after we conducted the final 13 exit.
14 During the assessment visits to the site, 15 several improvements were noted to us by the l
16 licensees.
One was that the licensee was more j
17 sensitive to reg. impact.
We were doing a lot -- they 18 were pleased with the announced inspection policy,
-T 19 although we found some problems with our announcement 20 of inspections during the assessments.
The public 21 workshops, the operator requal. program. Some of them 22 mentioned that inspector training and the t
23 professionalism had risen since they last -- since we r
24 conducted the survey.
25 There was
- also, on the other
- hand, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W I
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1 concerns regarding things we w / re doing. A definition i
2 of what constituted major a;tivities was necessary.-
3 Further improvements in an7ouncing team inspections,
{
i 4
credit for licensee initiatives.
That's someth'",
5 we're doing now with teara inspections.
If a licensee 6
decides to conduct t teir own inspection for a
f 7
particular area, we'll J eview the results of that and 1
8 make a determination as to whether or not we have to 9
conduct that inspection.
i 10 The assessment team composition.
One of 11 the things I didn't say, with the assessment tree, the 12 assessment
- guidance, ka were trying to ensure 13 consistency amongst all f ive regions with what we were j
14 doing in our assessment.
Another way of getting 15 consistency was to have t ne team comprised of several 16 of the same people. Threi people were the same in all 17 five assessments.
Mysel" as the team leader, Mike 18 Johnson, who is a section chief was one of the team 19
- members, and one staff i tember conducted or were 20 participants in all five assessments.
The team 21 generally consisted of si: members.
The othe'r 22 participants were the Assista7t Director for Projects 23 in NRR for the appropriate rtgion accompanied us on 24 these assessments.
The regional coordinators 25 generally -- they're from the Office of the EDO --
NEAL R. GRCSS COURT REPORTERS AND TRA iSCR:8ERS 1323 RHODE ISLAND AVENt E. N W (202) 234 4433 WASHINGTON, D C Pol M (202) 234-4433
16
-1 generally accompanied us.
I believe four out of five 2
came on it.
Then we used other staff from NRR, most i
3 3
of which had either resident or region-based i
4 inspection experience.
l t
5 Upon completion
.ot all five of the E
v 6
individual assessments, we integrated the assessments
. i t
7 results and came up with a national tree and a 8
national assessment report. We issued that assessment 9
report in August.
L i
10 Summary of what the findings were, the i
11 general perception is the inspection program was f
12 effective in meeting its regulatory objectives, in 13 evaluating the appropriate areas. However, some areas 14 have to be added.
There are certain places and I'll 15 get into that when I get into the improvements, where l
16 we have to devote more inspection effort and less in t
17 some others, and in identifying significant trends.
' t 18 other findings, the regions were very 19 effective in follow-up on events. 'All five regions, 20 as a matter of fact, on a national basis, came out 21 with significant strength for event follow-up, done 22 with-IITs, augmented inspection teams, AITs, regional 23 reactive teams and individual inspections.
P 4
24 Inspection findings were communicated in r
i 25 a timely and thorough fashion.
That's within the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234 4433 WA*,HINGTON. D.C 20005 (202) 234 4433 i
17 1
- region, between -the
- plants, with the resident 2
inspectors at the plants and between regions.
As I 3
said earlier, the core program was effective at the 4
good performances.
5
- However, several weaknesses were 6
identified.
One of the major ones was that the 7
inspection resources allocated and expended did not 8
match the licensee performance.
There was a poor 9
correlation between regions and within regions.
In 10 other words, some licensee with the SALP I and several 11 functional areas actually received more inspection 12 than licensee with a SALP III.
In some cases there 13 was a reason for it, there was justification for it, 14 but it is one of the weaknesses that we identified.
15 COMMISSIONER REMICK:
Last week we had a 16 briefing.
I think it was the one in the materials 17 area, if I recall.
As part of that we were told that 18 inspectors have a certain fraction of their time that 19 they're supposed to spend out in-inspections.
So, if 20 that's the case, if they're relieved in one area, that 21 means that they have to apply it somewhere else.
Has any thought. been given to how one is going to continue 22 23 a practice of inspectors having to spend X percent of 24 their time out inspecting if we are going to do what 25 Doctor Murley - mentioned is reduce resources where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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possible?
2 MR.
GODY:
And that's the answer.
3 Inspectors now are required to have 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> on-site 1
4 inspection per year, which is fairly reasonable.
[
5 That's about 28 percent of their time devoted to 6
inspection activities.
If we're talking about f
7 reducing -- the thing that has to be, we have to 8
reduce the size of the inspection force.
What we've 9
been saying is that what we're doing now is adequate 10 and maybe more than adequate and we just have to shift 11 some of the inspection resources to areas where we 12 have not been --
13 COMMISSIONER REMICK:
So, it would be a 14 reduction in people in the inspection area.
15 MR. TAYLOR:
Those percentages are higher 16 though for residents.
17 COMMISSIONER REMICK:
For residents.
i 18 MR. GODY:
Yes.
Oh, yes.
i 19 DOCTOR MURLEY: Yes, for senior residents.
20 MR.
GODY:
That was for region-based-21 inspectors.
Residents is approximately 50 percent.
22 COMMISSIONER REMICK:
And I can see where
~
23 regional you have that flexibility.
Where you have
~
24 residents, you don't have as much flexibility, even 25 though you might bring them back at the region and do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 234-4433 WASHINGTON. D C 20005 (202} 234-4433
19 1
other things, I guess.
2 MR. RUSSELL: The flexibility is there, it
-3 just takes more planning.
There's nothing that would 4
preclude you.from using a resident at one site to i
5 perform inspection activity at another
- side, or i
6 assigning other modules or other things to follow-up 7
on.
We've had this problem when it's core inspection 8
where it's generally the residents and N+1 tends to 9
drive the resources that go into the core program.
i 10 So, it-is a question of planning and in making sure 11 that those inspectors, whether they be generalist or 12 special inspectors, have the skills and the ability to l
13 do that.
So, it may involve some' cross training of i
14 inspectors or it may involve some advanced planning to 15 assign. inspectors from one site to perform an 1
16 inspection activity at another site.
]
17 MR. GODY:
If it was necessary to perform I
18 those activities at the other site.
What we've been 19 doing and what we're looking at now is not just 20 starting out with a certain amount of hours to be done 21 and working backward.
What we're looking at is what do we think is necessary to ensure safe operation of 22 s
23 a plant?
What inspections do we have to do and areas 24 do we look into?
Then we're going to say, we have 25 said, how many inspectors or how many inspection hours NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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20 j
1 i
1 are necessary to perform that activity?
Then from 2
that you go on down and you develop.
Given that we're 3
going to have them do either 30 percent, 50 percent, 4
whatever it is for that appropriate discipline, then 5
decide how many inspectors are necessary, not work it 6
backwards, work it from the ground up.
If it comes 7
out that we have too many inspectors, we have too many
~
8 inspectors.
9 COMMISSIONER REMICK:
Thank you, l
10 MR.
GODY:
Another area where we 11 identified weaknesses was management oversight of 12 inspectors was not consistently applied. We've got an 13 inspection procedure out requiring section chiefs, 14 branch chiefs and division directors to go to sites on 15 a
frequency of anywhere from one to three days 16 depending on what they are.
In some cases this has 17 proven to be unrealistic.
In the cases of small 18 regions it's got a larger impact on the licensee than 19 it does on us and we're asking to go to the sites too 20 often and the licensee has to accommodate that.
In 21 the larger regions, it looks like it's a proper mix.
22 However, the regions were not implementing it.
In 23 some cases people were not satisfying the guidance, 24 number one.
Number two, when they were going there-l 25 they were not doing what we expected them to do.
We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 2344433 WASHINGTON. D C. 20005 (202) 234-4433
t 21 1
1 had stories of managers going out, staying in the 2
resident's office and not providing feedback to-the 1
3 inspector, not attending the exit interviews and that i
i 4
type of thing.
So, we have to strengthen the guidance j
i 1
5 and then management of that particular area.
i i
6 CHAIRMAN SELIN:
Now, Mr. Gody, one thing l
7 that wasn't clear to me in reading the report is you t
8
-had some observations about management. -but did you r
9 actually go to the point of saying do we have either i
'10 too much oversight per inspector hour either in terms i
11 of number levels or just number of managers per 1
12 inspection hour, or did you take the structure as j
13 given,-take a look at the inspector hours and just l
14 scale that up?
l 1
15 MR.
GODY:
We took the management j
i 16 structure as given and did not look or make any l
l 17 decisions regarding any ratios of management to staff.
18 I think that's going to be going -- it has gone on for
}
19 Regions IV and V and it's going to be going on in a 1
1 20 future effort.
But we didn't look at that.
l 21 CHAIRMAN SELIN:
Thank you.
l i
1 22 MR. RUSSELL:
One comment.
The oversight l
I 23 policy and_ guidance is actually broken into two areas.
4 24 The first one addresses what types of activities we 25 want the management to be involved in when they're at NEAL R. GROSS l
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22 1.
the site, specifically what they're to be doing with 2
their time to be observing issues that are being 3
raised by the inspectors, to make judgments themselves f
4 about those issues, to interact with the inspectors, 5
et cetera.
6 The second part of the guidance is the 7
part that has got some benchmarks or some guidelines 8
in it.
They are not absolutes, but it does identify l
9 time on site conducting these kinds of activities.
10 They were estimates based upon what we felt was l
l 11 reasonable to accomplish the activities.
.That's the 1
12 area of the guidance both in what they were doing and I
s 13 how much time they were spending on site, that there l
14 were some shortcomings.
l 15 CHAIRMAN SELIN:
My observation was 16 somewhat different.
Coming from outside and getting j
I 17 familiar with the organization is a lot of middle 1
18 management at NRC.
It's not a question of. overhead 19 versus direct because an awful lot of technical work 20 is done by people that. are in principal-and--
l 21 supervisory positions.
But it has to do both with the l
22 numbers of levels and the number of really rather 23 small units that we have that.are being supervised.
l 24 But that was not part of the -- that was not even a 1
25 peripheral subject of the review.
NEAL R. GROSS CoVA1 REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 234 4433 WASHINGTON. D C. 20005 (202) 2344433
23 1
MR. GODY: No.. Span of control, that type 2
of thing, we did not look at.
We would have 3
identified it if it went the other way.
4 CHAIRMAN SELIN:
Effectiveness, right.
5 DOCTOR MURLEY:
Well, I need to comment, s
i 6
I think, here.
Going back to the regulatory impact 7
survey that we did in 1989, what we saw there was the f
8 impact of not enough management oversight. Inspectors 9
were out making policy for the agency basically.
10 Sometimes it was consistent with what we thought was 11 our policy and sometimes it wasn't.
So, we at that 9
12 time, as a follow-on to that, required the section i
13 chiefs and branch chiefs and division directors even i
14 to get out more.
15 CHAIRMAN SELIN:
Right.
16 COMMISSIONER REMICK:
I don't t.hink we're i
17 differing with that,
- Tom, at all because it's a l
18 question of number of managers versus management 19 oversight of employees.
I agree, I think now our j
i 20 managers are getting out and more directly observing i
21 the inspectors in the field and that's what the regulatory impact survey was saying that we should do.
22 23 I thought the point that Chairman Selin was making 24 that there are a large number of manager slots, 25 although they are related things, I think they're two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W, (202) 2344433 WASHINGT r.'< D C 20005 (202) 2344433 i
24 1
different points.
2 MR. TAYLOR: We understand the difference, I
3 yes.
4 MR. RUSSELL:
I guess just one additional 1
5 comment.
When we put the policy together, there was' 6
pretty much a senior management judgment that this was 7
important and needed to be done.
But we also got 8
feedback of what about all the stuff I used to be 9
doing that I'm not going to be doing anymore because 10 I'm now going to a site to oversee activities on site.
11 So, there are tradeoffs both ways and it does take 12 travel time and it takes time to get out.
You may 13 have a section leader that has responsibility for two 14 or more sites rather than just one and then branch 15 chiefs'that have several.
16 CHAIRMAN SELIN:
I would be disingenuous, 17 which although I have many vices, disingenuity is not 18 one of
- them, if I
said I
didn't believe that-19 throughout the agency we have too many levels of 20 supervision, too much time is spent reviewing other 21 people.
That's not the subject of this meeting.
My 22 question was just whether you took a look at that 23 question with respect to the inspection and the answer 24 was no, it was taken as given and if we needed ten I
l 25 percent more or ten percent fewer inspection hours, l
NEAL R. GROSS COURT REPORTE A$ AND TRANSCA!BERS 1323 RHODE ISLAND AVENUE. N W (202; 234 4433 WASHINGTON. D C 20005 (202)2344433 L_._________________
25 1
then presumably the recommendation would be increase 2
or decrease the numbers in proportion --
.3 MR. GODY: There's an overhead ratio, yes.
i 4
CHAIRMAN SELIN:
by the same ten 5
percent.
6 MR. GODY:
Right.
1 7
To go on, another identified weakness was 8
the core inspection focus on safety assessment and 9
quality verification and engineering and technical'-
i 10 support was insufficient.
As a matter of fact, there 11 was very little of it.
We're in the process of
!i 12 developing a
safety assessment and quality 13 verification inspection procedure where we will look l
14 at management control systems such as root cause 15 analysis, corrective action systems, off-site and on-
{
16 site review committees, self-assessment, third party l
t 17 audits, how licensees respond to audit and inspection l
18 findings.
Put that into the program and we will make 19 adjustments and take away from other areas.
l
-i 20 Also, engineering and technical support.
21 As far back as when we were doing the maintenance team l
inspections and then the ads fees, it was identified-22 23 that we had very little look at engineering and 1
24 technical support, a very important area.
So, we have 25 developed and are about to issue a new. inspection NEAL R. GROSS COURT REPORTERS AND TRANSCRIDERS i
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~
-26 1
procedure'in that area.
2 CHAIRMAN SELIN: What's the reverse of the 3
coin?
What were the areas that we're getting an 4-excessive amount of it?
5 MR. GODY:
Maintenance observations by 6
resident inspectors where we told them to look at four 7
activities per month, not paying any attention to what 8
the significance of those activities were and that 9
type of thing.
10 CHAIRMAN SELIN:
So, it wasn't that there 11 was insufficient inspection, but it was insufficiently 12 divided by doing the risk analysis or the engineering' 13 analysis or the safety assessments.
They looked more 14 here than there because there's a higher payoff for 15 problems found here.
16 MR. GODY:
Right.
17 COMMISSIONER ROGERS:
I'm just a little 18 concerned on that point myself or that bullet as to 19 really what kind of increase in activity you
'20 contemplate.
What will the inspections be looking at.
21 that they _ weren't looking at before in safety 22 assessment or engineering support?
23 MR. GODY:
They'll actually be looking at 24 engineering and on-site work being accomplished and we 25 hadn't looked at it. We hadn't looked at calculations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202 D44433 WASHINGTON, D C. 20005 (202) 2344433
i 27
{
1 to any extent.
We hadn't looked at --
2 COMMISSIONER ROGERS:
But it will be 3
looking at the results of the engineering work, is l
i 4
that right?
5 MR. GODY:
Right.
i 6
COMMISSIONER ROGERS: Rather than how many l
t 7
engineers they have on-site or something like that?
8 MR. GODY:
No.
No.
That's not the way 9
it's geared.
The other thing you asked, where will we I
10 take it from?
I didn't want to get into numbers, but 11 in the existing inspection program we've got about 25, 12 27 percent of the inspection activity devoted to area f
i 13 of emphasis inspections which are generic area teams 14 and other special inspections.
Historically the 15 regions have only been expending about ten percent of
- i 16 the inspection effort on those areas, leaving us a 17 considerable amount of resources to apply to other 18 areas.
That's the type of thing we're going to be i
19 doing. We've been over expending in the core area and 20 we're going to adjust that to make it more realistic l
t 21 as to what we actually do need.
22 MR. RUSSELL: These two findings were'also l
23 factored into the SALP program revisions and we found 24 that, in fact, the guidance to inspection of what we j
25 wanted people to look at both in the area of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASHINGTON. D C 20005 (202) 2344433 i
f 28 i
i T
1 engineering and in.the decision to have' safety P
.2 assessment quality verification c.It across the four i
3 areas and then be addressed specificelly in the cover 4
letter, we found that we really had r.ot put out good f
f 5
concise guidance as to what constituted those areas.
i 6
It had built uo with judgment somewhat over time and 7
there was actually little inspection guidance from the 8
standpoint of what should be done in those areas, i
9 particularly in the engineering area, i
lu CHAIRMAN SELIN:
Actually I'm getting the i
11 impression -- and I'd like to say this so if I'm vrong i
12 you'll correct me.
You're basically saying you're 13 breaking the tight connection between resident 14 inspectors and core inspections, that there are tasks l
15 to be done and there are people to do them.
f i
16 MR. GODY:
That's right.
}
i 17 CHAIRMAN SELIN:
And that some of the i
18 tasks that are not core inspection tasks'that would i
i 19 change from time to time can be carried out by 20 resident inspectors if they're properly trained and 21 directed.
22 MR. GODY:
And vice versa.
i 23 CHAIRMAN SELIN:
Sc., that tight connection 24 won't be so tight --
1 25 MR. GODY:
Right.
t NEAL R. GROSS i
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29 1
CHAIRMAN SELIN:
-- in the future.
2 MR.
GODY:
.And vice versa.
Like the i
t 3
regional initiative, which is about a third of the i
4 program, where the regional administrators direct 5
resources to where they see fit.
That could be any i
6 type of inspector that's qualified to do the job.
t 7
COMMISSIONER ROGERS:
Well, you now, I a
8 don't wan to belabor the point but I am concerned j
9 about how the inspections are going to be conducted, 10 let's say of the engineering and technical support.
t 11 It does seem to me that it isn't possible to take an l
12 average resident inspector and ask that person to look i
13 at the quality of an engineering assessment.
They 14 might or might not be capable of doing that.
i 15 Therefore, how do you propose to do that?
16 MR. GODY:
Right now we have the program 17 split up where about two-thirds of the inspection 18 ef fort would be performed by region-based inspectors, 19 engineering inspectors, and some of it, another third, 20 would be done by the resident inspectors mainly 21 because they're on-site, they have a
window of 22 opportunity to look at modifications, installations 23 and that type of thing which would follow-up on what 24 the region-based inspector looked at in the 25 engineering office.
We would go look and they would NEAL R. GROSS COURT REPORTERS AND TRANGCRIBED.S I
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review calculations.
3 2 ~
CHAIRMAN SELIN: You're basically arguing, 3
if I understand correctly, that if the communications t
4 were better between the region and resident inspector 5
and the assignments were more explicit that some of 6
the follow-up work can be done efficiently by resident l
7 inspectors.
8 MR.
GODY:
- Yes, but communications 9
generally are very effective between the resident and 10 the regions.
I think they do it on daily basis.
The 11 regional administrators could attest to that.
They 12 usually are very good communications.
One of the 13 strengths in the program _was communications.between 14 regions and between the residents and the region-based -
15 inspectors.
They complement one another.
So, they 16 would -- the region-based would take a look at the 4
17 actual engineering and the resident can take a look at 18 the implementation of those. activities.
19 MR. RUSSELL:
Some good examples are the 20 motor-operated valve inspections that are done where 21 we look at engineering and how they've done set-up of 22 the valves, the electrical system design inspections, 23 service water inspections. Some of these have aspects
- 24 of engineering design evaluation as well as t
25 operations.
So, they can split the inspection group NEAL R. GROSS COURT AEPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W t?D2i 2344433 WASHINGTON D C. 20005 (202) 234 4433 i
-31 i
1 up and.there may - be some aspect's that look at' l
2 operations performance associated with biofouling or 3
things like that that can be done by a resident and i
i 4
you may be having engineering looking 'at heat removal, 5
some of the design calculation issues.
j 2
i 6
MR. GODY:
Some of the regions are doing f
i 7
that and were doing it.
Even though we didn't have an i
(
8 inspection procedure that said engineering and 9
technical support, the regions with the regional 10 initiative developed their own and went out and looked 11 at these activities.
Region III in particular did j
12 that.
13 CHAIRMAN SELIN:
Just like your 14 introduction.
i 15 MR. MILLER:
Two facets to engineering, 16 there's the classical design engineering function at.
j i
. 17 plants and then there's t.. t close support that's j
18 performed by the technical staff to operations and j
19 maintenance.
The element that was not explicitly 20 covered in the core program was the second part that 21 addresses how engineering supports maintenance on a 22 day to day basis, how they follow-up on equipment when 23 it fails to get good root cause evaluation.
- Now, 24 we've covered that in different ways.
Residents have 25 picked up much of it, the region-based inspectors have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE !$ LAND AVENUE, N W (202) 234 4433 WASHINGTON. D C. 20005 (202) 2344433
=..
i f
32 i
1 picked up much,'but it wasn't explicitly covered in i
2 the core inspection program.
I think'the regions have l
3 been ' working very closely with NRR to develop an t
4 inspection module, if you will, that would address 5
that area.
It's a very important area.
6 COMMISSIONER ROGERS?
It still sounds to 7
me more like a process though than the quality of the 8
engineering itself. It's the relationship between the i
9 engineering and maintenance that you're looking at.
j 10 MR. MILLER: Well, our focus has been, and l
11 I assume the other regions as well, is very much on i
5 12 product.
Pull the string on a valve that fails.
Why i
i 13 did it. fail?
What kind of preventive maintenance or
'l i
14 predictive maintenance was done on that valve or not i
I 15 done on that valve?
So, much less the process, much
~f 16 more what engineering contribution there has been to f
17 the situation, but looking at it through actual 18 performance.
i 19 MR. RUSSELL:
We also do get support from 20 contractors where we need it where we bring designers 21 in to assist with the design reviews. - For example, on P
22 the electrical system design inspections, we typically l
23 had three contract designers that would assist us with 24 the details of the calculations to supplement staff.
}
25 Where the region may have had that same capability in-NEAL R. GROSS COURT REPORTEF4S AND TRANSCRIBERS j
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1
33
.1 house, we'd use fewer contractors to support it.
2 We're doing the same thing in other areas.
We also 3
look into come of the reloads and the fuel issues.
4 For example, the issues that we had with WNP where we 5
provided support.
t 6
So, it's really trying to provide a focus j
t 7
to the engineering area that was spread out and really l
8 didn't have a focus before.
We've identified that it I
9 is significant and important and what we're trying to t
10 do now is identify what would be the core program for 11 sampling in that area so that you've got a basis for.
12 making a judgment overall in the engineering area.
i 13 MR. GODY:
(Slide)
I'm going to put up 14 the national inspection program assessment tree and i
15 just.briefly go over that.
16 In the area of inspection program 1
i 17 effectiveness, you'll notice there are three areas 18 where we've identified significant strengths. One was t
19 the core inspection procedure and it being adequate t
20 for good performing plants.
That sounds strange, but i
21 we wanted to make sure we were at least giving them 22 enough of a look to ensure that they were sustaining l
i v
23 the good performance.
i 24 I mentioned earlier the reactive resources l
l 25 used to respond ' to significant events and issues.
NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W f
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l 34 1-That was a strength.
As a matter of fact, I believe l
2' that was a strength in all five regions.
And 3
inspection findings communicated across regions to 4
Headquarters and within a region.
That we identified 5
as a
strength.
Then under inspection program 6
implementation or execution, the event follow-up was 7
the strength.
8 As you look at it, we identified several 9
areas, those are in yellow, that require improvement.
10 In both the core and the regional initiative, the 11 effect has to be consistent with industry performance.
12 It was not.
What follows that is over in the area on 13 execution, inspection planning.
That has to be I
14 strengthened to ensure that you have the appropriate 15 amount of resources devoted to the appropriate 16 licensee.
17 Inspector oversight, as I
mentioned
.l 18
- earlier, that needs improvement and inspector 19 utilization. Again, that has to do with the resources 1
20 and the licensee's performance.
And again, the last 21 thing was inspection report format.
As I said, we 22 reviewed 100 inspection reports and --
\\
23 CHAIRMAN SELIN:
If you read
- this, 24 basically it supports Doctor Murley's view that there
)
i 25 isn't an excessive amount of management in the field NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS 1321 RHODE ISLAND AVENUE, N W (202; 234 4433 WASHINGTON D C 20005 (202) 2344433 l
c
l 35 j
1 with the inspection program, that all the areas that J
2 you say need working have to do'with --
3 MR..GODY:
Management.
t I
4 CHAIRMAN SELIN:
-- management.
5 MR.
GODY:
Yes.
But that doesn't j
6 necessarily mean it's because we don't have-enough l
7 managers.
8 CHAIRMAN SELIN:
It might be that the 9
structure is inefficient, it might be you do have i
i 10 enough, you don't have enough managers, priorities i
11 might be different.
They may be weighed down with'
~
i 12 Commission requests instead of doing the work.
There 13 are a lot of theoretical possibilities.
.t 14 MR. GODY:
Oh, yes.
i 15 DOCTOR MURLEY:
Keeping this place 16 informed takes a lot of time. Everybody wants to know 17 everything instantly.
i 18 CHAIRMAN SELIN:
But this is mostly the 19 regions we're talking about, right?
20 MR. TAYLOR:
Yes.
i r
21 MR. GODY:
Yes.
And it's the program 22 also, changes that we have to make to the inspection 23 program itself.
As a matter of fact, I would say 24 there is more work we have to do on the program than 25 the regions have to do with implementation of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
1323 AHODE ISLAND AVENUE, N W i
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1 program.
2 CHAIRMAN SELIN:
Okay.-
i 3
MR. RUSSELL: We also conduct inspections
+
4 out of Headquarters and need.to take the lessons to 5
heart'also in the planning and. oversight area.
r I
6 COMMISSIONER REMICK:
Yes.
I find this 7
assessment tree concept, which is similar to what you f
8 used in the maintenance inspections, is a very good j
i 9
communication tool to give you a feeling, of broad l
10 areas and where are the problem areas and the good i
11 areas and so forth.
I still feel to be an effective 12 way for SALP programs rather than numbers.
But 13 putting that aside, I think it is an effective way.of' 14 displaying the overall program.
15 MR. GODY:
Yes.
16 COMMISSIONER REMICK: There's one box down i
17 here, training and qualification, which is green and 18 I don't differ with that.
Back in 1989 the ACRS made
{
19 a
recommendation that the agency undertake some 20 research on what makes a good inspector and I think i
21 that was perhaps misunderstood.
The reaction was 22 somewhat negative because the arguments made were that 23
'a lot of training is provided to inspectors and I 24 think that's true and I think it's good training.
25 But the thing that the ACRS had in mind, NEAL R. GROSS COURT REPORTERS AND TRANSCR!BERS 1323 RHODE ISLAND AVENUE. N W.
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1
t 37 1-at that' time in the late '80s there - was a l'ot of-2 criticism of' inconsistencies and arm-twisting and so 3
forth that was going on and I think what the ACRS was 4
trying to get at, do we really know what makes a good 5
inspector and what makes a bad inspector?
And if we 6
knew what makes a good inspector, are we making sure
-i 7
that that's the type of training we're giving, not.
.i 8
only the technical training and procedures and so 9
forth, but are there other aspects of being a good 10 inspector that should be addressed and perhaps are not 11 being addressed?
I don't know if any additional 12 consideration has been given to that.
13 It's kind of like in a way related to the 14 job and task analysis where you determine what it is 15 a person has to do and then you ask yourself, "How are 16 we going to make sure that he has the tools to do 17 that?" I don't know that we've ever done such a thing 18 as organized as that for inspectors, but, I think, as 19 I say, I thought the recommendation was misunderstood 20 back in
'89.
Perhaps it wasn't adequately described.
21 Have we done anything like that?
Do we 22 have any plans?
23 MR. GODY:
No.
24 COMMISSIONER REMICK:
It isn't a question 25 that they're getting training and the training is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 2344433 WASHINGTON. O C 20005 (202)2344433
- - -. I
~. _.
'38 I
J l
good.
It's a' question is it wh'at they really need.
4 2
MR. GODY: They get a suf ficient amount of f
3 tachnical training.
A 4
COMMISSIONER REMICK:
Yes.
5 MR. GODY:
What you're talking about is,
~
6 is this going to be a good parent or a poor parent, a 7
good inspector, a very subjective area, and to my I
8 knowledge I don't think we're doing anything in that i
9 area.
10 COMMISSIONER de PLANQUE:
In the 11 information paper you mentioned you put a new module 12 in on the fundamentals of inspection and you tried 13 that out earlier this summer.
Any evaluation of that 14 yet?
15 MR. GODY:
No.
16 COMMISSIONER de PLANQUE:
Is it too soon 17 to really --
18 MR. GODY:
It 's too soon. That's going to 19 be extremely difficult.
They had pilot training in a 20 couple of regions and there's a group now looking at e
21 the Fundamentals of Inspection course and seeing 22 lessons learned from the pilot training courses.
23 COMMISSIONER de PLANQUE:
But this seemed 24 to be aimed more at those other areas.
V 25 MR. GODY:
I know, and I personally think NEAL R. GROSS 1
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l 39 1
it's going to be very difficult to --
2 COMMISSIONER de PLANQUE:
To evaluate, 3
yes.
i 4
CHAIRMAN SELIN: I rcight just follow-up on I
i 5
Commissioner Remick's remark.
In the software 6
- industry, which is the industry of which I'm a 7
graduate, there's always the question about what makes 8
a good programmer.
What we found was the best thing 9
to do was everybody knew who the good programmers 10 were, so, instead of doing a theoretical analysis, we 11 looked at the best people we knew and we found out how 12 they differed from the other people.
There were 13 significant differences.
I mean, they're irrelevant 14 to inspection, but these were people who had very good 15 verbal skills as opposed to mathematical skills, which I
16 was a surprise until you realize that programming is 17 very much a
question of syntax much more than 18 computation.
19 But sometimes the easiest way to find out 20 what makes the best of a class is to see if you agree 21 on who the best of the class is, and most people do, j
22 and then find out what makes them different from --
I 23 you know, how are they different from the other 24 people, a very simple empirical --
25 MR. GODY:
I think we'll find the skills NEAL R. GROSS COURT HEPOATERS AND TRANSCRIBERS 1323 AMODE ISL AND AVENUE N W
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40 1
are no different, the attributes that are desired are 2
no different for a programmer than they are for an i
3 inspector too.
It's good communication skills, 4
ability to let people know what you're thinking. That 5
type of thing would apply here also.
i 6
Unless there's other questions, I'll move 7
on to the proposed improvement actions.
These are 8
pretty much self-explanatory, but we do intend to 9
modify the inspection program.
As a matter of fact, 10 we've already staN.ed to do that.
11 Also have the regions improve their 12 planning, this would be a little more dif ficult.
The 13 region administrators are going to be --
14 CHAIRMAN SELIN:
One thing that came 15 across really more when you delivered the SALP 16 briefing than here was the difference of philosophy.
17 It's not just sort of grading the amount of effort up 18 and down depending on whether the licensee is --
19 Commission Remick would prefer there be an " honors" a 20 "high pass" and a " pass" than a 1,
2, and 3, and I 21 appreciate
- that, but basically it's saying the 22 function of inspection is not to do things from 23 scratch but to validate work that the licensee does in 24 the area if the licensee does that work.
I mean, 25 that's a very powerful concept.
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You're not.just saying let's do 2,200 2
hours instead of 2,4 00- hours, but you're saying let's 3
do something different.
Let's find out that the 4
licensee has done the work himself and, if so, is it 5
good enough to be validated or do we have to go out 6
and reproduce it?
That part was pretty clear.
7 It's not clear to me if there are other t
8 places where you're really doing something 9
qualitatively different and not just a little more if I
10 it's a weak licensee and a little less if it's a i
11 strong licensee.
12 MR. GODY: Okay.
That has to be done too, i
13
- though, the correlation of the effort to the 14 licensee's performance.
That's important.
I i
15 In the engineering and technical support j
16 area, that is an area that we have to look at that's 1
17 going to provide results, looking at the licensee's 18 almost entire organization.
19 CHAIRMAN SELIN:
Let me say this 20 differently.
It's a big dif ference between saying I'm 21 going to take a two percent sample on a strong 22 licensee and a three percent sample on a weak licensee t
23 to say we're not -- you know, we're going to certify 24 the work rather than reproduce it.
I mean, one is i
25 just a question of grading the quantity compared to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. f4 W.
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the a
priori. probability. you're going to find 2
something.
The ther one says the focus at least of 3
that one part oughc to be _ qualitatively different from 4
what we've been doing with certain of the team 5
inspections.
6 MR. GODY:
And in what way.
7 CHAIRMAN SELIN:
Are there other areas 8
where you've come up with an approach other than just i
9 sort of shading of resources?
10 MR. RUSSELL:
There are two areas we're 11 looking at.
12 One I mentioned at the SALP briefing and 13 that inspection procedure has been issued and it has l
l 14 been quite well received.
That is.where you have a 15 dialogue with the licensee in advance in an area of i
16 interest and the licensee identified to you how they 17 propose to inspect that area themselves and who they 18 will use to do it.
The second phase of that, we would 19 monitor the actual implementation of that agreed upon 1
20 plan.
And the third phase would be to review the 21 results of that with the licensee informing us of what 22 they found and what corrective actions they're going 23 to take, and I indicated we will use that as input 24 into both the licensee's ability to self-assess their 25 own performance in a technical area as well as NEAL R. GROSS
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43-1 providing an incentive by way of reducing resources of 2
the major team inspections.
3 The other area that we're looking at l
4 shifting and we have an initiativa ongoing in NRR to 5
look at this and we're having dialtgue with industry, i
6 and that is to develop a more per.iormance-based or 7
graded approach' toward QA reviews in the quality 8
areas, not in the audit assessment.
9 We are working also in the audjt l
10 assessment as it relates to self-assessment, as Tony 1
11 mentioned, and we're working on developing guidance as 12 to how they assess, collect inputs from various r
13 activities, whether it is from NRC findings, INPO 14
- findirgs, their own findings from their '2A audit l
15 function, or whether it's from an on-site engineering 16 group or whoever it is, how they pull those together, 17 assess them and develop corrective actions is in the 18 area of safety assessment, quality verification.
P 19 But we're also changing the approach on QA I
20 from a standpoint of looking at areas the licensee has i
21 assessed, did they find problems, and that's probably l
22 an area we would not go in and look in if we had 23 confidence.
But if there were an inspection finding l
24 by the staff, we would ask questions. Had they looked 25 in that area?
If they had, did they find these type NEAL R. GROSS l
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of problems?
If they did, why didn't they do 2
something about it?
If they didn't, what.does that 3
tell you about their assessment approaches?
So, we 4
are making some changes in those areas.
5 We're also looking to how we might use the l
6 approvals that have been reached with' industry under 7
the maintenance rule of identifying the. relative 8
importance of things to be maintained, and that 9
covered the scope of maybe 60, 70 percent of the plant f
10 equipment.
Once we reached agreement on a process to 11 identify that which is important, there may be some 12 opportunity for using that in making audits as it 13 relates to engineering quality or other areas.
We 14 have not completed the work on'that, but we've had
.15 dialogue with NUMARC and with industry, so we're 16 working in those areas.
17 CHAIRMAN SELIN: Are you talking about the f
18 interim inspection guidance or once the maintenance 19 rule goes in?
20 MR. RUSSELL:
No.
What I'm talking about 21 now is in Reg Guide 160.
We've reached agreement on 22 a
process for identifying the risk significant 23 activities for the maintenance rule when it goes into 24 effect in the future and how that insight in those.
25 findings can be used.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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45-1 CHAIRMAN SELIN: Okay. - I understand that.
2 Are you planning on doing anything with the interin j
3 inspection guidance based on those insights before the 4
maintenance rule goes in?
5 MR.
RUSSELL:
We. had not planned on 6
revising.
We did make one -- I guess there are two 7
exceptions.
We did update the guidance and we are 8
also proposing a generic letter that would allow 9
elimination of accelerated testing for emergency 10 diesel generators based upon voluntary adoption early 11 of the maintenance rule as it applies to the emergency 12 diesel generator.
So if they would want to follow 13 that example and go to a performance based approach 14 including root cause analysis for failures, we would 15 eliminate the requirements for accelerated testing.
16 And that is out for comment now.
In fact, we just 17 briefed the ACRS on this last month.
So those are 18 some areas we're also making changes in our approach.
19 What Tony was discussing was how we assess 20 this overall based broadly upon the performance 21 categories we use for SALP, so we're going to try a:.d 22 correlate inspection modules to SALP categories, look 23 at how many hours were expended and then be able'to 24 correlate how much total resources went in. That will 25 cause us to raise questions about an area, then we'll NEAL R. GROSS COURT HEPORTERS AND TRANWRIBERG 1323 RHODE ISLAND AVENUE. N W 4202) 234 4433 WASHINGTON. D C 20005 (202) 2344433
t 46 i
1 have to dig the next-layer down to find out why there 2
are differe'nces if there are some.
f 3
MR. GODY:
I think the safety assessment' 4
and quality verificmcion procedure that we're 5
developing will answer some of that.
As I said 6
- carlier, it's the management control systems that r
7 we'll be looking at and how they're addressing their 8
own first how they're identifying their own 9
problems and then how they're addressing them.
10 Haven't gone into a lot of detail in the past in that l
11 particular area, i
12 So we have several improvement actions 13 that we are going to be putting into place and 14 developing and they have to do with improving the 15 planning, better correlation of inspection resources 16 for licensee performance, improve the management 17 oversight activity area, the inspection guidance for l
18
- SAQV, inspection guidance for engineering and 19 technical support.
i 20 We're revising the program to reflect the i
l 21 SALP process.
The inspection program is the primary 22 input to SALP, so SALP ic going to-four functional i
I 23 areas plus SAQV, in a sense, and we're changing our 24 inspection program to better prepare input to that 25 process.
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We're going to redistribute resources for 2
the' core, regional initiative, and area of emphasis.
\\
3 Actually,'the regional initiative will stay the same.
4 They've been using around 32, 33 percent of their l
4 5
resources for that.
The core we're going to have to L
6 add some resources.
And the area of emphasis, the.
f 7
generic area teams, we're going to decrease the amount 8
of resources allocated to that area.
9 One of the things that came up, questions i
10 that the Commission asked was, if we did reduce -- as 11 a matter of fact, if we reduce resources by five or 12 ten percent or increase resources, what would we do to 13 monitor licensee performance?
How would we pick up i
14 any declines in performances?
l 15 What we've decided is pretty much what.we i
16 have in effect now is working to give us an early
.l 17 warning if a licensee's performance is declining.
18 Those are reviewing the results of independent 19 inspection, the plant performance indicators that have i
20 been in use for some time, the SALP performance trends
{
l 21 and the SALP
- ratings, enforcement history and l
i 22 enforcement trends, periodic plant reviews that the
[
23 regions conduct semi-annually and some on a quarterly 24 basis for the licensees it's a mini-SALP, so to P
25 speak, for the licensees in that particular region --
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our senior managemenc meeting.almost all of this feeds 2
into when our senior managements get together and make 3
some determinations as to licensee performance, and we 4
intend to continue these assessment activities.
5 That's the extent of my briefing..
6 CHAIRMAN SELIN: You've run out of charts, 7
so that must be the briefing.
8 MR. GODY:
That's it.
I'm done.
9 CHAIRMAN SELIN:
No, no.
That's the end 10 of the briefing.
11 Doctor Murley's opening remarks basically 12 I think illustrate a certain dilemma that we have, 13 that over time most of these performance indicators 14 that we have are starting to approach an asymptote.
i 15 They-really have.
Except for safety system 16 actuations, they've all leveled off in the last couple l
17 years and you would expect that if, in fact, all the j
i 18 plants are excellent.
l I
19 Now if the top guys are getting pretty 20 close to where they're going, but there's still this 21 big spread between the top and the bottom folks and 22 the bottom folks were improving their performance --
23 I don't mean an' individual plant because the watch 1
24 list comes and-goes, but if the average -- you know, 25 if you think of this as
- a. population where the NEAL-R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W (202) 2344433 WASMNGTON. D.C. 20005 (202) 2344433
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performance of the top guys is more or less constant
-j 2
but the performance of the bottom people overall is 3
improving so that the average is coming up slowly, you 4
would expect that we would not be reaching the 5
saturation in the safety system or'the other -- I'm 6
sorry, the performance indicators.
~
7 In other words, I look at the performance 8
indicators and it seems to me that the bottom l
9 performers are not improving as fast as they ought-to i
10 improve.
We should be seeing more of an improvement 11 over all the safety -- I mean, the performance 12 indicators than we are.
i
?
13 The first question is, am I reading these-l 14 wrong or are we still seeing insufficient progress at l
15 the weaker performers coming closer to the stronger
}
16 performers?
17 And then the second depends on the first.
5 18 There are lessons from the inspection program other 19 than just grading the amounts?
I mean, should we be l
20 doing dif % rent kinds of inspections at the laggards 21 from the kinds that we're doing at the better people?
1 22 MR. GODY:
One thing we've found.
The j
23 good' performers that are identified by the senior i
~
24 management meeting, they take very little inspection 25 effort.
As a matter of fact, applying the whole NEAL R. GROSS COURT HEPORTERS AND TRANSCRISERS 1323 ftHODE :SLAND AVENUE. N W i
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1 50 i
I 1
' program takes less. time than it does at a-poor l
l 2
performer.
3 The really poor performers, the ones that 4
are on the senior management list, they get more than l
5 enough attention.
They're devoting their own 6
attention to themselves.
We're putting a -lot of i
7 effort into it.
8 What worries us is what's.in the middle.
9 It's almost like -- it's a normal distribution, just f
10 about.
At the top end, you have half a dozen plants.
i 11 At the bottom you have half a dozen plants.
It's that 12 95 in the middle that you have to worry about, because 13 the poor performers within that group, they're the 14 ones that are potential senior management meeting poor 15 performers..
Most of the inspection effort would be 16 devoted at that particular group.
The - regional 17 initiative would be spent there. Once they're on that 18 list they're taking a good look at themselves and j
19 we've done just about all we can do.
As far as 20 identifying weaknesses, they're already there.
21 CHAIRMAN SELIN:
But the folks in the 22 third quartile need--
23 MR. GODY:
Yes.
t i
24 CHAIRMAN.SELIN:
Do they need attention 25 that's qualitatively different from the kind that NEAL R. GROSS COURT REPORTERS AND TRANSORIBERS l
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we're giving them today?
I mean,.that third quartile 2
isn't really getting better as fast as it ought.
3 MR. GODY:
They do need the attention.
4 They're not getting the attention now.
5 CHAIRMAN SELIN:
Can-I ask the regional 6
folks?
7 MR. EBNETER: That's exactly right from my 8
view.
It's that middle section, and we have several'
~
9 of them in region II, that have been stagnant for l
10 years.
11 If you look at a Pareto plot of Region -II f
12 plants of ours versus SALP scores, they line up pretty 13 good now.
That wasn't true before Tony came.
We've 14 readjusted the --
i 15 CHAIRMAN SELIN:
The inspections to fit
~
16 the statistics.
i 17 MR. EBNETER:
Well, at least the numbers l
I 18 come out better.
)
i 19 But I
think that's true.
The poor 20 performers we do put a lot of effort on, and over a 21 period of two to four years they become good i
22 performers.
They really do.
Turkey Point is a 23 classic example, and Surrey.
It's that middle bunch 24 that does not get the resources or maybe a different 25 type of inspection, as you have noted, to maybe NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W.
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52 1
motivate them a little-more or to do-something with 2
them to make them improve at a faster rate, but that 3
group seems to be pretty constant.
4 MR. MILHOAN: I guess I'd agree with Stu's 5
comments.
6 I think one of the problems is not the 7
inspection resources devoted to the poor performers l
8 but the uncertainty in the inspections that are 9
necessary to detect a decline in performance for the 10 middle category plants.
It's always in the back of 11 your mind.
Have you detected that change in 12 performance soon enough so that you can apply the 13 additional resources necessary to quantify that change 14 in performance?
15 CHAIRMAN SELIN: Those middle folks should l
16 be getting better slowly but surely.
They're not so 1
17 bad that they're going to get dramatic improvement 18 from one year to the next, but, if you hold them up 19 against the best in their class, you can see there's 20 a significant difference that's not explained by the 21 design of the plant or the original quality.
22 MR. MILLER:
The same perspective.
23 CHAIRMAN SELIN:
Commissioner Rogers?
24 COMMISSIONER ROGERS:
Well, I think this 25 is a very interesting effort.
I am a little bit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (202) 2344433 WASHINGTON, D C. 20005 (202) 234 4433
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i 53 t
~1 concerned that it moves more towards performance-based l
2 inspections rather than process-based inspections.- I 3
know that's your philosophy. I mean, that's something j
4 we've been moving more and more towards and, Bill, l
1 5
your statements seem to give me some reassurance on i
i 6
- that, but it is a matter that ' concerns me with i
7 inspections because that's always where we can start i
8 to exercise an attempt to tell the licensee exactly 9
how to do everything, and to me that's the wrong way 10 to go, but we do want to hold them accountable for i
t 11 results.
i i
12 I like the little outline that you gave in 13 your description in one area of how they would propose i
14 to do something and we would hold them to achieving j
15 those results and it seems to me that's a good way to I
i 1
16 go and I like it very much.
But I just have a i
l 17 concern, and it may be a misplaced concern, that we.
18 may be mixing performance-based regulation with 19 looking at processes and, if I'm wrong on that, I hope 20 I am, because I think that's not what we should be 21 doing.
j 22 MR.
RUSSELL:
I would hope we could l
23 characterize it that we're moving slowly from what we
)
24 were doing in the process area before.
We still have 25 some of
- that, but we're trying to introduce NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS j
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performance-based inspection activity as well.
We've 2
made fairly substantial cutbacks in the area of l
3 specialist inspection in physical
- security, in
[
4 emergency preparedness, and in regional health
.[
t 5
physics, as the regional administrators would be able 6
to attest from the standpoint of what we've done in f
i 7
budget space and reallocation, and that's resulted in
[
8 the need to cross-train and hire in some different i
9 areas. And now we're focusing on engineering and some i
10 alternative approaches to inspection.
But it's going 11 to be a gradual change.
It's not going to be a j
12 revolutionary process.
13 COMMISSLONER ROGERS:
Well, I just wanted 14 to say I'm pleased to see that we're doing it.
I 15 think that it represents a very serious effort and I 16 think that we have to keep it up, keep the resources, 17 our resources applied to this to see some results.
18 That's all I have.
I 19 CHAIRMAN SELIN:
Commissioner?
20 COMMISSIONER REMICK:
I strongly support l
4
?
I 21 the need for stronger management oversight in the l
22 inspection activities and I'm pleased that we're doing i
23 more of that.
Just from one or two data points, I.
t 24 know that it is being done.
What kind,of feedback 'are 25 you getting from say regional personnel now going out f
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W i
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55 1
and observing inspectors, but also sitting in on the 2
exit interviews end so forth?
Exit meetings, excuse 3
me.
~ Are you getting any kind of - feedback of what 4
they're finding?
Any surprises since they're out 5
there observing the inspectors more?
6 DOCTOR MURLEY: You mean, for example, the 7
regional section chiefs and branch chiefs?
8 COMMISSIONER REMICK:
Yes, actually going a
9 out and s}.ending more time with inspectors and sitting 10 in on the exit-meetings and so forth more frequently.
11 MR. MILLER:
I think it's always been a 12 vital part of inspection is the management oversight.
t 13 I think what has happened after the regulatory impact 14 survey is to set some goals to perhaps enforce that a l
15 little more stringently.
16 I
think it tends to be, -
from my 17 observation, more of an observation inspector by 18 inspector. 'I don't know that there's any pattern that 19 I've seen come out of this and maybe that's why you're l
l 20 not getting a quick. response here.
But we have f
21 clearly seen cases where you get insight on how
.j i
.22 inspectors are doing, well or poorly, and that, of i
23 course, gets reflected in performance appraisals and 24 steps to improve.
25 MR. EBNETER:
I think the biggest thing I NEAL R. GROSS COURT REPORTERS AND TRANSCRfDERS 1323 RHODE ISLAND AVENUE, N W.
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56 1
see out of it there is more contact'with licensee 2
management because they do go to the exits more often 3
and the licensee has more of a direct input to the 4
management, the line management.
I think it's 1
5 valuable from that standpoint.
You realize the 6
inspectors are on their best behavior when you go out I
7 with them.
i 8
COMMISSIONER REMICK:
Even regional I
i 9
administrators when the Commission goes, right?
10 MR. EBNETER:
True, true.
11 CHAIRMAN SELIN:
Stu told me it was the 12 other way around, the Commissioners are on their good 13 behavior when they go out to the regions.
14 MR. MILHOAN: I guess I see one additional l
15 thing impact in addition to the management oversight j
16 of the inspectors with the additional management time 17 at the site is the supervision and the ragion 1
i 18 management, I
- think, have a
clearer picture of i
19 understanding of what is going on at the particular
(
20
' sites and I think.that makes for a better input into l
21 the SALP process and for a lot more overview of 22 licensee performance.
23 COMMISSIONER REMICK:
Thank you.
24 Bill, going back to something you said.
25 about when we have an inspection finding and a logical NEAL R. GROSS COURT REPORTER $ AND TRANSCR:BERS i
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questien is.why didn't the-licensee pick this up in 2
the self-assessment process and I agree it's a logical-3 thing.
But just very recently I. heard a concern t
)
l 4
expressed by a licensee that thef.r self-assessment 5
programs were being used against them.
The results 6
are being used against them and this had a chilling 7
effect on their willingness to want to conduct self-8 assessments or make them readily 'available to the i
9 staff.
10 I'm wondering in light of what you just l
11
- said, is there a
possibility here there's a
12 miscommunication from the licensee on why we might be 13 looking at self-assessment?
I mean is there a full 14 understanding of --
i 15 MR. RUSSELL:
I'm aware of comments being 16 made in that context, particularly as it relates to 17 what I will characterire as prudency issues.
I have 18 not heard that with respect to NRC findings.
I have 19 heard it in the past.
Where a licensee brings forward 20 an issue to an inspector, the inspector characterizes
)
21 the issue.
The licensee then reads about it in the 22 monthly inspection report-or at an enforcement-4 23 conference and they don't seem to get the --
24 COMMISSIONER REMICK:
It was this latter 25 context, yes.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W (202) 2M4433 WASHINGTON D C. 20005 (202) 2344433
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.=
F 58 1
MR.
RUSSELL:
credit for-self-i 2
identification.
3 COMMISSIONER REMICK:
Right.
4 MR. RUSSELL:
I think that's a management 5
philosophy issue that we need to get out.
We clearly 6
rely upon the licensees to operate these facilities.
7 It's their responsibility for safety, not ours, and 8
what we are trying to do through this process is 9
encourage them to find their own problems.
}
10 COMMISSIONER REMICK:
Right.
I agree.
11 MR. RUSSELL:
I characterize that if you 12 have a
self-revealing problem or NRC finds the 13 problem, we're going to be asking questions about that
.)
14 issue and why did you not act on it before had you I
15 known about it.
In fact, I just discussed this.this 16 week with the non-operating owners and the owners when 17 they got together in Philadelphia, the approach we're 18 taking to self-assessment and what our expectations 19 are and some of these initiatives to move toward a 20 nore graded approach toward quality assurance that 21 we're working with industry on.
And, by the way, 22 working with the regions, we've already had our first 23 counterpart meeting with all the regions as well.
~
24 So, I think this is going to be a 12 to 18 j
25 month effort to really put these concepts in place and i
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59 i
1 then some period of time of experience with them.
But 2
it is the direction we're moving.
3 DOCTOR MURLEY:
But with regard to your I
1 4
basic question of are we having a chilling effect by 5
some actions' that we do, a licensee's own self-
^
6 assessment program, I have not sensed that. There may 7
be some isolated cases.
I guess I'd like to hear from 8
the regions.
9 MR.
EBNETER:
No,
I agree with you, l
10 Commissioner.
I get those comments too.
But -it 11 mostly occurs -- the enforcement policy forces us into 12 some of those molds if the licensee does a self-13 assessment or there's a self-revealing problem, and it 14 clearly violates some safety function, then we take i
i 15 enforcement action on that even though the licensee 16 has identified it.
They really resent that, but 17 that's our present policy.
18 MR. RUSSELL:
Yes.
For self-revealing or 19 NRC identified, we would take full enforcement.
But f
20 we can mitigate up to severity level ' 3, but we 21 typically issue a notice of violation even though
.i.
22 there may not be civil penalty action.
23 COMMISSIONER REMICK:
And I don't know in
)
l 24 the particular case I'n referring to where the person
.)
25 made a comment it was enforcement action or not.
I I
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N W (2021 234 4433 WASHINGTON D C. 20005 (202) 234-4433
60 1
perhaps probably should have pursued it in that I
2 direction.
So, I really don't know if it was a case r
3 of that or --
4 MR. EBNETER:
It's prudent and in all of 5
my meetings with my staff on enforcement-issues in 6
particular, the first question I ask them is who found 7
it.
Occasionally you'll find a case where there's 8
some reluctance to admit - that the licensee but 9
generally the staff is pretty straightforward on it.
10 MR. GODY:
More often than not the report 11 will say it's a licensee-identified item.
12 COMMISSIONER REMICK:
In the enforcement 5
13 action?
14 MR. GODY:
No, in the inspection report.
15 COMMISSIONER REMICK:
Oh, inspection 16 report.
i 17 MR. RUSSELL:
We're trying to get that in 18 the inspection report.
19 COMMISSIONER REMICK:
Good.
I thank you 20 very rauch.
21 CHAIRMAN SELIN:
Commissioner de Planque?
22 COMMISSIONER de PLANQUE:
The j
23 inconsistency problem is one you hear about all.the' 24 time when you're circulating out there in the 25 community and I hear it mostly in the sense of j
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61 1
inconsistencies from region to region.
But obviously l
t 2
it's plant to plant even within regions.
And to some l
3 extent you want that if you're going to have ' it
+
4 consistent with performance.
What of'all the actions 5
that you're taking do you think. will really address l
6 the inconsistency problem and, if it is addressed, how 7
can that really be communicated out there?
8 MR. EBNETER:
Well, probably the major 9
action is just what Tony did.
He went through and 10 identified where we're not very consistent and there 11 were some good findings in there.
Other than that, we '
12 try at least through our training programs and general 13 meetings to make sure at least within the region that 14 we're consistent.
But my guess is we'll never be --
15 you can't clone everybody.
i 16 MR. MILLER:
I think one of the things we 17 have found very valuable are counterpart meetings on 18 selected topics.
I can think of motor-operated 19 valves, for example, where there have been any number 20 of meetings between the program office and the I
21 regions.
We find that very important, especially in 22 those areas where appropriately our guidance is not-l 23 highly prescriptive.
-l 24 COMMISSIONER de PLANQUE:
Right.
)
25 MR. MILHOAN:
I would think internally-to i
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62 1
the region, as Stu said, I think one of the most 2
important things that we can do is improve the 3
communications within the region with respect to i
4 conduct of inspections, holding workshops on different i
5 inspection areas of how to conduct a good inspection, 6
peer review of inspection reports within the region, n
7 feedback to inspectors cn quality of inspection 8
reports and that's very important to consistency 9
within a region.
10 MR. EBNETER:
There are several comments 11 in Tony's basic report about the inspection program is l
12 a function of the individual inspections, inspectors, l
13 several cases of it and that's why it's important for 14 the management oversight. And that's absolutely true.
15 We have a lot of different inspectors. They don't get 16 a
lot of management oversight and the regional l
t 17 inspector is on travel.
.itween travel time and on-18 site time, 40 percent (f his time he's not even
+
19 accessible to his supervisor.
The resident inspector i
20 is even less accessible. His dealings are through-the 21 telephone.
)
c-22 So, it's very difficult for the line 23 managers.
If you talk about consistency, it's even 4
24 more difficult under those circumstances.
25 COMMISSIONER de PLANQUE:
Yes.
Okay.
)
NEAL R. GROSS 323 AH DE S D A ENUE,
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Very good briefing.
2 CHAIRMAN SELIN:
- Actually, you did a j
3 report last year that showed that in terms of the SALP i
4 scores the variation from region to region have'gone 5
cown considerably over the last five years, but the 6
other half is that the variation, not by region but of 7
inspection hours, uncorrelated to SALP scores, was 8
really quite bad.
9 MR. RUSSELL:
Yes.
i 10 CHAIRMAN SELIN: And I think that supports 11 what Mr. Ebneter said, that once the spotlight turns 12 on these issues they tend to get straightened out.
13 Did I
read in your notes that 14 Commissioner Remick convinced me without too ~ much 15 trouble of the idea that we should be reviewing the 16 requal programs and not the requals.
Did I read that 17 that review is going to be at the resident inspector's 18 level to take a look at the --
l 19 MR GODY:
It will be region-based
\\
t 20 inspections.
21 MR. RUSSELL:
There may be some feedback 22 back because the residents may observe some training 23 as a part of their program, but the intent is to use 24 the examiners and to cross-train them to become 25 inspectors to follow-up on these areas and then use NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N W (202) 234 4433 WASHINGTON. D C 20005 (202) 234 4433 1
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64 1
either observation of utilities examining review of 2
actual exams or, in a last resort, administering our 3
own exams to judge performance.
But we want to make 4
it performance-based inspection.
That's probably the 5
most performance-based inspection we have, is when we 6
go to the final step of examining, or simply observing 7
them conduct the exam.
So, this is really getting 8
leverage by observing someone else do it.
9 CHAIRMAN SELIN:
Either Doctor Murley or 10 maybe Mr. Russell, what do you see the connection with l
11 the findings at this level which are in principle very 12 short-term with what's coming out of the regulatory 13 review group which also talked a lot about inspections j
14 but other activities that will effect the inspections?
15 Do you see the kind of changes that is being talked 16 there as dovetailing with the changes here?
How are 17 they tied together?
18 DOCTOR MURLEY:
With regard to the 19 inspection program, I do, yes.
Generally, in fact, 20 they rely very heavily on this assessment for their 21 conclusions.
So, I don't see really any significant 22 differences.
23 CHAIRMAN SELIN:
Okay.
I would just like 24 to make one observation and that is you've got to get 25 the core programs down because there are always NEAL R. GROSS COURT RE PORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N W s202) 234 4433 WASH 2NGTON D C 20005 (202) 234 4433 N
65 1
surprises and'if everybody has programmed 95 2
percent -- you know, last year it was shutdown 3
operations. The year before was electrical problems.
4 There's always going to be some. area that 5
we become aware of so that there has to be some spare 6
capacity in the system to pick up -- not boiling water 7
level indicators.
I mean there's a' big issue every 8
year or more and we need to have the -- I won't call 9
it the routine, but the plannable,. predictable work 10 under some control so that there's some capacity to 11 pick up these things.
12 MR. GODY:
There is.
There is currently.
13 You've got the regional initiative, which I said 31 l
14 percent of the inspection resources are devoted to 15 just this type of thing if something comes up.
The 16 area of emphasis inspection, when we have a particular 17 safety concern in an area, we'll concentrate resources 18 from there.
19 CHAIRMAN SELIN:
I misunderstood what you 20 meant by regional initiative.
I thought that was a 21 set of problems that particular plants or the region 22 decides that they have a particular --
23 MR. GODY:
That too.
24 CHAIRMAN SELIN:
-- problem.
But, you' 25 know, the couple years I've been here there have been i
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three or four major. -- the fire inspection, the 2
boiling water level indicators, the follow-on and the 3
shutdown operations, that have really been very time 4
and effort rich that have had to have been picked up 5
and not predicted at the time.
6 MR. GODY: Yes. And resources from region 7
initiative are devoted to this.
It makes it more 8
difficult for the regional administrators because we 9
just tap that well.
10 MR. RUSSELL:
But we have reduced it.
At 11 one point in time we had two major team inspections 12 basically going in parallel.
We've essentially 13 dropped those to the point where we have one at a time 14 and we've been-phasing them so that there is some 15 backing off in those areas.
But I agree, we're going 16 to see something different next year.
If we continue i
17 having steam generator problems with.'the way they're-18 aging and inspections and more replacements, that's 19 clearly going to take more of our resources.
20 CHAIRMAN SELIN:
That was really an 21 excellent presentation.
The Q&A was illuminating.
22 It's really very good work to be encouraged on all 23 avenues.
It's a very good initiative, very good 24 follow-on.
4 25 Thank you very much.
)
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(Whereupon, at 4:22 p.m.,
the above-I 2
entitled matter was concluded.)
3 l
4 5.
6 7
.i 8
9 10 11 k
12 l
13 14 15 4
16 1
17 i
18 i
4 19 20 c
21 22 23 24 j
)
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 13?3 RHODE ISLAND AVENUE. N W i
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CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING:
BRIEFING ON NRC REACTOR INSPECTION PROGRAM ASSESSMENT AND PLANNED IMPROVEMENTS PLACE OF MEETING:
ROCKVILLE, MARYlJtND DATE OF MEETING:
SEPTEMBER 20, 1993 were transcribed by me. I :arther certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
Laur m u/
' /
Reporter's name:
Peter Lynch HEAL R. GROSS cout7 asooaTWtS AND TRANSCRistit5 1333 RHODG ISLAND AYtMUf. M.W.
(202) 234-4433 WASMM670N. D.C.
2000$
(202) 232-6800
6 ASSESSMENT OF NRC REACTOR INSPECTION PROGRAM September 20,1993 T. Murley S. Ebneter W. Russell J. Milhoan A. Gody H. Miller 1
BACKGROUND e
inspection Program Substantially Revised in 1987 o
Program Tied to Licensee Performance o
Recognized Growing Role of Team inspections o
Established Regional Initiative Regulatory impact Survey Conducted in Fall of 1989 o
improve Coordination of Team inspections o
improve Management Oversight e
N + 1 Resident Program implemented 1989 o
Residents on site by 1991 o
Fully implemented 1993 Detailed inspection Program Assessment Process Developed in 1993 2
INSPECTION PROGRAM ASSESSMENT Objective - Evaluate the Operating. Reactor inspection Program to Determine If:
Regulatory Objectives are Achieved Appropriate Areas are Examined o
Resources are Applied Consistent With industry Performance The Program is Consistently implemented on a National Basis 3
ASSESSMENT DEVELOPMENT Inspection Program Objectives and Evaluation Measures Established (SECY-92-169)
Assessment Methodology Developed o
Structured Assessment Tree o
Detailed Assessment Guide e
Regional Comments on Assessment Methodology Resolved Provided Assessment Tree and Guide to the Commission on April 13,1993, in Memorandum from J. Taylor on Assessment of Reactor inspection Program 4
ASSESSMENT METHODOLOGY Review Inspection Program Effectiveness o
Core inspection Program o
Regional Initiative inspection Program o
Area of Emphasis inspection Program Review Regional Inspection Program Execution o
Management o
Planning o
Performance o
Documentation 5
ASSESSMENT METHODOLOGY (continued)
Focus on Key issues of Effectiveness and Consistency o
Significant issues Found Before Self-Revealing o
Core inspection Effort at Good Performers Effective o
Emerging / Existing Safety Concerns Addressed o
Effort Correlation with Industry Performance 6
ASSESSMENT ACTIVITIES EACH REGION i
2 Week in-Office inspection Related Documentation and Data Review 1 Week Regional Office Visit e
2 Reactor Site Visits to Review Implementation Preliminary Exit by Assessment Team o
Final Exit by Deputy Director, Office of Nuclear-Reactor Regulation and Assessment Team Leader e
Regional Assessment Report 7
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ASSESSMENT TEAM COMPOSITION (Six Members)
Participants in All Five Assessments Assessment Team Leader Section Chief Staff Member Additional Participants Assistant Directors for Projects Regional Coordinators from the Office of the EDO Other Office of Nuclear Reactor Regulation Staff 8
l l
l ASSESSMENT ACTIVITIES l
NATIONAL e
Integrated Regional Assessment Results e
Compared Generic Safety issues to inspection Program Activities National inspection Program Assessment Report e
issued (SECY-93-241, 8/25/93) 9
f
SUMMARY
OF RESULTS The inspection Program is Generally Effective in:
Meeting its Regulatory Objectives Evaluating the Appropriate Areas 5
Identifying Significant issues / Trends 10 h
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Identified Weaknesses e
Resources Did Not Match Licensee Performance e
Management Oversight of Inspectors Not Consistently Applied e
Core inspection Focus on Safety Assessment / Quality Verification and Engineering / Technical Support was insufficient e Adjustments Can be Made to Allocated Inspection Resources to Reflect Historical Expenditures 11
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PROPOSED IMPROVEMENT ACTIONS Modify the Inspection Program and improve Planning to Ensure inspection Effort is Consistent with Licensee Performance Reduce Overall Inspection Effort Based on Savings from a Better Correlation of Inspection Resources with Licensee Performance improve Guidance and implementation of Management Oversight Activities 13
a PROPOSED IMPROVEMENT ACTIONS (continued)
Develop inspection Guidance in Safety Assessment /
Quality Verification issue inspection Guidance for Engineering / Technical Support 1
Revise inspection Program to Address identified Weaknesses and Other Lessons Learned Revise Program to Reflect the SALP Process 14
MODIFIED INSPECTION PROGRAM R:
ice Resources Based on Analysis of Requirements Redistribute Resotarces for Core, Regional Initiative, and Area of Emphasis inspections o
Core - Add Resources for SA/QV and E/TS, Expand Maintenance, and Add Requalification Exam inspections Regional Initiative - Distribute Based on Licensee o
Performance o
Area of Emphasis - Decrease Based on Historical Effort 15
c MONITOR IMPACT OF RESOURCE CHANGES ON INSPECTION PROGRAM EFFECTIVENESS Review Results of Independent inspections Review Plant Performance Indicators Review SALP Performance Trends and Ratings Review Enforcement Trends Periodic Plant Reviews Senior Management Meetings Ongoing Assessments Activities 16 a
--