ML20114F717
| ML20114F717 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/10/1981 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML19255H970 | List: |
| References | |
| FOIA-84-44 NUDOCS 8202160174 | |
| Download: ML20114F717 (5) | |
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UNITED STATES
!%.,7 i NUCLEAR REGULATORY COMMISSION 2 c.QW*j ;
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DEC 101901 MEMORANGUM FOR:
Nerman C. Moseley, Director, PDA:!E FROM:
James G. Partlow, Chief, PAB:PDA:!E THRU:
James M. Tayle., Deputy Director, PDA:IE SUBJICT:
INPO EVALUATION AT PLANT HATCH During the period Octcber 26 - November 5,1981, I observed an INPO evaluation at Plant Hatch.
l The following notes present background information and my impressions of the INPO Evaluation Program:
The INPO team travelled to Baxley, Georgia, on Sunday, October 26, and arrived at the site at 8:00 AM on !!cnday. The first day was cor
$n hdaymorning, a mini-exit was ieto with plant management and the team returned to Atlanta that afternoon. The team returned to Baxle
'a mM y
i afternoon. Evaluation work was conducted c although a gcod portion of Wednesday was spent in wrapping up t e team's I
" Findings" and briefing E. P. Wilkinson and Zack Pate (Head of the Evaluation
(
and Assistance Division) who arrived Tuesday evening. Messrs. Wilkinson and Pate, accompanied by the Plant Manager, took an extensive plant tour on Wednesday. Team meetings with Wilkinson and Pate were held on Wednesday j
afternoon and evening. The exit meeting was held on site on Thursday morning and tha team then returned to Atlanta (more on the exit meeting later).
i however, tne evaluation criteria t
has not yet been completed. Final approval of these procedures involves utility concurrence by the INPO Industry Review Group and some unofficial shake-down testing.
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The aress covered by the evaluation included: Organfration & Administra-tion, Training, Operations Maintenance, Technical Sepport, and Radiation Protection / Chemistry.
an.valu aa to assist in areas as needed; a total of The Hatch evaluation team consisted of fourteen people during the first week and nine during the second. The extra people were mainly in an indoctrination / training status.
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l Norman C. Moseley DEC 101331 4
1 The Hatch team included a Team Manager as well as a Senior Team Manager (an IN?O Department Head). The use of a Senior Team Manager full-time dur,,in,g an. evaluation, is probably only temporary until such time as a y qualified Team Managers are developed. M
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plans are t The Hatch team had the following general qualifications:
Team Manager - Former Senior NRC Resident Inspector. Held SRO license i
as a utility employee.
Team Members - Five members of the team had utility experience as SRO or RO.
A sixth member had served as an Engineering Cepartment Heaa in the Navy nuclear program. The HP had utility experience and HP certification.
rather than detailed line items to be checked during each evaluation. INPO relles on the experience and judgment of their Evaluation Specialists and management reviews in the fleid and at INPO headquarters to ensure that the scope and depth of their evaluation is consistent from plant to plant. I understand that the June 1981 version of the Performance Objectives is currently being revisad and improved. I suspect that they will be somewhat more detailed than at present, but they I
will not apprcach the detail of the checklists which were once used.
Free my limited INPO experience, I see several differences in scope, depth, and methods between INPO evaluations and our Performar.ce Appraisal Inspections.
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Scope & Depth: As mentioned above, INPO is still gearing up to evaluate j
corporate activities. While the PAT teams take a concentrated look at
)
I CA Audits, Committee Activities, the Corrective Action System, Cesign Changes, and Procurement, INPO examines these areas to a lesser degree as part of "
ort and 0 r i * * * ~ a sy a n va
- criteria, irclude Chemistry contro, urve....
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o=t Systems, Plant Reliability M"**On-siteReactorEngineering,anoc.ergencyrreparecness.
tene emergency Preparedness portion is handled setarately frcm the regular evaluations in conjunction with the annual plant drill and was not observed by me S ccmparing overall scepe and depth, it should be noted that a typical evaluation involves n
-- h a ~ag actual on site evaluation activities for about five days inspec' 4n involves six people on-site for about 12
-avever allow them to visit each plan wnereas S is on a
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schedule.
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l Norman C. Moseley DEC 10156 I
l Method: While I don't want this point to be over emphasized, there seems to be a difference in approach between INP0 evaluations and PAT inspections.
PAT systematically and exhaustively works through the Ifcensees written program, spends a considerable amount of time with licensee personnel to determine their qualifications and awareness of prcgram requirements, and then ends up with a relatively short look at how well the program is being implemented.
In the areas of Organization / Administration, Technical Support, and Trainin2, INPO generally follows this sace scheme although the scope and depth may be differen the areas of Operations, Maintenance, and Radiation Protection ends to work '
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..,-. - nce wuring eac:) eva uation, a rv manes speci ic plans to coserve piant operations such as diesel or HPCI tests, start ups, major maintenance work, or a Radwaste shipment. Their observations on goed practices or "
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These speciff in the INPO report unless they are individually of significant importance or collectively point to a general area of weakness.
The desetopment of " Good Practices" and " Findings" for the exit meeting and the final report follows a trend similar to that in PAT. Deficiencies identified by individual evaluators are discussed during team meetings, nal 1
The Hatch exit meeting was held on-site and lasted for just under two hours. In addition to the principal plant staff, it was attended by four levels of Corporate Officers - from Vice President, Nuclear to Executive Vice President, Georgia Power.
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e til O nas agreen to keep me informeo as tnis process continues or naten.
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1 Norman C. Moseley gg1' El Sy the end of CY-81, INPO will have corpleted their first round of evaluations at all cperating plants. During the second round 1
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the avaluation method will - -*'
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f11 In preparation fcr this, I uncerstand that If4PO is considering asking each utility to supply them with a summary aval fon.
TFie of the status of impr a~
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As INPO completes its second round and expands with more evaluation teams, I 1
expect that we will see an increased empt. asis on " assistance" visits -
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4, appears that ItJO will precao some plants will stay at this frequency, some will nave a -
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'a*waaq evaluations - with the average being perhaps on th On several occasions, I discussed with Messrs. Wilkinson and Pate the i
subject of how the results of INPO Evaluations might be recognized and utilized in the NRC inspection program. Given the similarities between an INPO Evaluation and our own Performance Appraisal (PAT) Inspections, we agreed that we should at least continue to share schedules in order to avoid conflict in our visits and an undue burden upon the utilities.
We also discussed the possibility of either INPO or PAT " skipping" a facility which had recently been reviewed by the other - although that would be difficult to arrange with INPO on a 12-18 month schedule and PAT completing a round every 3-4 years.
Of course, one obvious way to " recognize" the results of INPO evalua-tions would be to acknowledge them in the basic NRC inspection program in a manner similar to what has been done for PAT and SALP results. Basically, our program says that Regional Administrators gy relax the normal insoection j
frequency in those areas which have recently received a favorable Performance l
Appraisal Inspection or SALP review. The program does not say that they should or must do this; and it does not say that they should or must increase the inspection tempo in areas which are generally found to be unfavoracle, l
out three basic criteria some time sgo:
a.
NRC review of other party criteria, procedures, evaluation guides, etc., should show adequate coverage of licensee performance areas.
b.
NRC review of other party inspection process should show expected j
standards of capability and professionalism.
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I Norman C. Moseley DEC 19 l?31 i
NRC should be given prompt access to the results of inspections c.
by other parties.
avenues for receiving progra.n cescriptions, and the fact that I was i
included in the Hatch evaluation with full access to all pertinent I
information is indicative of INPO's willingness to work together.
Keeping in mind the current differcaces in man-days per PAT Inspection /
INPO Evaluation and the fact that INPO evaluates some areas which PAT does not, INPO's increased emphasis in the following areas would more i
j closely align Evaluations with the general thrust of current Performance Appraisal inspections:
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j Corporate Office Support and Oversight Activities of On-Site and Off-Site Committees g
Management Systems for Corrective Action j
Effectiveness of the QA Audit Program I
ognizing that INPO is, and will probably remain, a relatively small organization 5
(less than 300 people) and is involved in several programs other than Utility Evaluation, I believe that the evaluation effort is under the leadership of excellent, highly dedicated management, and their people l
l authority and support in acnieving improvements in nuclear operations.
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i (thus dec aring it a puo ic document), it is possione (nat some INPO reports would have
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that such accisionai in ormation cousa ce gaineo tnrcugn a review of supporting background documents and discussions with appecpriate INPO 1
4 personnel. I think that we would also want to occasionally acccmpany
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an INPO evaluation in order to stay current on their program.
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Jarps Partlow, Chief Preyram Appraisal Branch, POA:IE 11 4
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$U \\DPQ JAh 11 ISS2 t'r E. P. Wilkinson, President Institute of f uclear Power Operations 1820 llater Place Atlanta, Georgia 30339
Dear N. Wilkinson:
We have r.vfewed the description of yoJr Sfgnificant Event Evaluation and i
Infomatfor. 'fetwork (SEE-IN) program provided by your letter of August 6,1981 The purpose a..' objectives of the program and the mechanics for its f=ple-mentation, as descrf bed in your report, appear to adequately support the collection, evaluation and af sserination of operating experience. Your program appears to effectively consolfdate operating experience events, such as LERs.
Into one data assessment program.
tie believe that the SEE-I'! program will make a signiffcant contribution to reactor safety. At the sa:.e time, it will relieve the individual nuclear plant operators of the necessity of setting up large staffs to obtain and screen the large volume of raw data certainini to oMeattenal exceaf **** *W-Mut n-_
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.m The NRC/AE00 has a f*emorandum of Agreement with INPO under w vou are e
lar transmitti the results of e an We look forward to seeing a copy of the revised SEE-IN program which consolidates the whole program at INP0.
Sincerely.
0Hehr firew 17 H. R. Cantas l
Harold R. Denton, Director Office of Nuclear Reactor Regulation CISTRIBUTION:
Central Files R. Vollmer LGB Reading B. Snyder H. Denton J. Kramer E. Case D. Yassallo PPAS
- 5. Cavanaugh - NRR-81 449 N. Thompson LQB Members
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