ML20148M862

Forwards IE Evaluation of Trial Resident Inspector Program. IE Should Proceed W/Plan to Locate Inspectors Near Certain Reactor Sites

ML20148M862
Person / Time
Site:	Three Mile Island
Issue date:	03/16/1977
From:	Volgenau E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
References
TASK-TF, TASK-TMR SECY-77-138, NUDOCS 7811220214
Download: ML20148M862 (51)

Text

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garch 16, 1977

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• NUCLEAR ~ REGUL4 TORY COMMisslON W ASHING TON, D. C. 20555 SECY-77-138 INEORMATION h m3 . 097 REPORT l For: The Commissioners From: Ernst Volgenau, Director, Office of Inspection ana Enforcement Thru: Executive Director for Operatione

Subject:

LOCATING NRC INSPECTORS NEAR REACTOR SITES -

TRIAL PROGRAM

Purpose:

To forward the IE Evaluation of the Trial Inspection Program and to inform the Commission that IE proposes to preceed with planning to locate inspectors near certain reactor sites.

Issue:

Does locating an NRC inroector near a reactor site result in a more effective and efficient inspection program?

Discussion:

The current NRC reactor inspection program is carried out by inspectors who are assigned to an NRC Regional Office which may be located as much as searal hundred miles from a reactor site where inspections are to be performed. Under this arrangement, implementation of the program requires ins'pectors to travel between the Regipnal Office and the reactor site at various of lengths intervals time. of tim'e and to remain on-site for various A concept of'" resident inspection" was pro-posed in 1974, in which an inspector would be assigned full I

time to a to assigned location

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nearOffice.

a Regional reactor sites rather than being A trial program which applied .

this proposed resident inspection concept to inspection of  !

operating reactors was developed to provide a basis for evaluating the concept. This trial inspection program was implemented at two locations, including four reactor sites and five reactors during 1974 and was planned to extend for two years in order to obtain information necessary for an adequate evaluation of the trial program. .

The p-incipal benefits expected from the concept of resident inspection being evaluated were as follows:

Increased on-site inspection time, F

Improved NRC awareness of the facility activities, and Increased inspector efficiency.

CONTACT:

B. H. Grier, IE 7811220p$ D 49-27356 c_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ L

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Realization of these benefits would provide NRC with increased assurance of the safe conduct of licensed activi-ties. The major concern associated with the resident concept was the potential for loss of inspector objectivity because of the inspector's close day-to-day association with the licensee.

Factors to be included in evaluation of trial program effective-ness and efficiency were delineated prior to commencement of the program. The principal factors to be evaluated were the following:

Impact on safety of operations, Accomplishment of the inspection program, Budgetary impact, Impact on inspector, and Licensee reaction.

Trial Program

Description:

The trial irispection program for operating power reactors was initiated in June 1974 by stationing the first " resident inspector" at Two Rivers.;iWisconsin, with responsibility for inspection of the Kewaunee and Point Beach Unit No. 1 and Unit No. 2 facilitier. In Sep'tember 1974, an inspector was stationed at Benton Harbor, Michigan, and assigned inspection responsibilities for the Palisades and D. C. Cook Unit No. 1 facilities. The scope of authority and responsibility assigned the trial program inspectors was consistent with that assigned inspectors operating from the Regional Office. The management and supervision of the trial program was under the Region III Office (Glen Ellyn, Illinois). The trial program was terminated in October 1976.

Evaluation:

The Office of Inspection and Enforcement has now completed its detailed evaluation of the trial program. The results of this evaluation are documented in Enclosure 1. As a basis for the evaluation, the evaluation team received input from the licensees, trial program inspectors, and regional supervision; made first-hand observations at the sites; and reviewed the inspection reports and other docucentation associated with conduct of the trial program.

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Summary of

Conclusions:

IE has concluded that the trial program has demonstrated that the concept of locating inspectors near reactor sites is viable, and under certain cir cumstances, is the preferred method of inspection. The specific conclusions are as follows:

1.

Inspector effectiveness was improved through increased direct observation of facility operations.

2.

Because of inspector location, NRC awareness of facility status was enhanced due to increased on-site time and ability to respond to facility problems.

3.

Inspector acceptance by the licensee was enhanced, resulting in easier access to facility records and increased inde-pendence of inspection effort.

4.

I Licensee effort in capport of the NRC inspection procest, was reduced.

5.

Licensee management at}ention to NRC requirements was enhanced. '

6.

There is no significant budgetary impact associated with the inspection concept.

7.

Application of the inspection concept is restricted by the availability of qualified inspectors and candidate locations.

8.

There was no indication of loss of inspector objectivity '

associated with the trial program.

9.

From the standpoint of increasing the effectiveness of the NRC inspection program, locating an NRC inspector near the reactor site is the preferred alternative for:

[

-- A cluster of three or more operating reactors within a radius of approximately 25 miles. .

-- A single or multi-unit facility during the preoperational testing /startup phase.

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10. Nothing was identified in the trial period which suggests l that the inspection concept is not applicable to reactors under construction.

Imolementation:

The Office of Inspection and Enforcement proposes to implement a program of locating inspectors near power reactor facilities in the testing and operations phases. The effectiveness of  ;

the concept will be continuously evaluated during the imple-mentation and any necessary corrective action, which may inciude termination of the program, will be promptly effected.

Commencing in fiscal year 1978, IE plans to station inspectors at five locations. In fiscal year 1979, inspectors will be stationed at 13 locations. Full implementation of the concept described in this paper is planned by fiscal year 1981 with inspectors at 35 locations.

The reactor facilities which are presently candidates for this program are identified in Enclosure 2. It should be noted that each power reactor facility becomes a candidate as it begins the activities associated with preoperational and startup testing. ,

4.

To fully evaluate the feasibility of locating NRC inspectors near power reactor facilities under construction, IE proposes to initiate a two-year trial program in fiscal vear 1976. Candidate facilities fer this trial program are ident fied in Enclosure 2.  ;

Related Study:

l Further study is underway to identify how much and what kind of reactor inspection provides adequate protection of the public and the environment. This study includes an assessment of a full-time federal employee in the reactor control room. The results of this assessment will be available in sufficient time for Commission consideraticn in developing a response to l the petition for rule making which includes this issue (SECY- l 77-51).  !

Other related issues under study include: core direct measure-ment versus records review by NRC inspectors, the use of mathematical and statistical techniques in the inspection l program, application of techniques of other regulatory organiza-tions, etc. Although complete information on some of these l

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issues may not be available for a year, it is hoped that enough information will be available in the next few months in order to have an impact on the formulation of the fiscal year 1979 budget. This information will be presented to the Commission by July.

In the meantime, planning will proceed for locating inspectors near reactors. Both the planning and the fiscal year 1978 initial implementation will be structured so as not to conflict with subsequent Commission decisions regarding the petition  ;

and the fiscal year 1979 budget.

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'Ernst Volgenau Director Office of Inspection )

and Enforcement

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Enclosures:

1. Evaluation of the Trial Inspection Program }

2. Candidate Sites ..

DISTRIBUTION Commissioner's  !

Commission Staff Offices I Exec Dir for Operations i Regional Offices j Secretariat '

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January 2& 1977 l EVALUATION OF THE TRIAL RESIDENT INSPECTION PROGRAM OFFICE OF INSPECTION AND ENFORCEMENT U.S. NUCLEAR REGULATORY COMMISSION Evaluation Team

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Edward B. Blackwood, Reactor Inspection Specialist, Division of Reactor Inspection' Programs a

Ramon E. Hall, Chief, Engineering Support Section, Division of Field Operations, Region IV Edward L. Jordan, Chief, Engineering Support Section, Division of Field Operations, Region III 6

Reviewed by: 2/viatt F- tic 96. L/

Jdmes H. Sniezek, Chief)

Light Water Reactor Pr69 tams Branch?

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,. Approved by: A, s 4/ k [

/Boyce/h. Grier, Director Division of Reactor Inspection Programs ENCLOSURE 1

. I TABLE OF CONTENTS Section ~Page

1. Abstract . . . . .......'.......... 1

2. Introduction . . . . . . . . . . . . . . . . . . . 2  !

3. Trial Program Description ............ 4 s

3.1 Execution . . . . . . . . . . . . . . . . . . . 4i 3.2 Evaluation Basis ............... 4

4. Trial Program Results .............. 6 4 .1 Accomplishment of Inspection Program . .... 6 i 4.2 Inspection Manpower Utilization . . . . . . . . a 12 4.3 Safety of Operations .............. 19 4.4 Inspector Awareness . . . . . . . . . . . . . . 24 I 4.5 Supervisory Effort .............. 26 4.6 Administrative and Support Functions ..... 26  !

4.7 Qualitative Judgments... . . . . . . . . . . . .  !

28 4.8 Impact on Inspectors ...........

30 5

5. Licensee Reaction . . . . . . . . . . . . . . . . 34 i

6. Related Experience ............... 36

7. Summary and Conclusions . . . . . . . . . . . . . 37 7.1 Benefits ................... 37 7.2 Costs . . . . . . . . . . . . . . . . . . . . . 39 i 7.3 Conclusions . . . . . . . . . . . . . . . . . . 39

8. Recommendations . . . . . . . . . . . . . . . . . 41 i

8.1 Direct .................... 41 i 8.2 Related . . . . . . . . . . . . . . . . . . . . 42

9. References ......'............. 43

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EVALUATI0?l 0F THE TRIAL RESIDEllT It1SPECTIOl1 PROGRAM

1. ABSTRACT A two-year trial resident inspection program was initiated during

' Fiscal Year 1975 at two locations; the first included three operating power reactors, the second included one operating unit and one reactor plant in the test and startup mode. The objectives of the trial program were to evaluate benefits anticipated from the resident inspection con-cept, and to determine the economic and programmatic costs of this inspection technique. This evaluation of the costs and benefits indicates that the resident inspector concept is a viable concept preferred for selected applications; however, its application may be limited because of stringent personnel requirements and the availability of suitable locations. Inspection benefits and improved inspector utilization have been demonstrated; however, because of limited availability of suitably qualified personnel and appropriate facility locations, selective application of the concept is recommended.

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2. INTRODUCTION Management of the reactor inspection program by the Atomic Energy Commission was initially centralized in regional offices which were already established to carry out the materials inspection program.

During the 1960's and early 1970's, this centralization was necessary to optimize inspection activities at a time of low inspection frequency and limited resources. As the power reactor industry has expanded, inspection of power reactor facilities has become the predominant inspection activity. Because of the anticipated increases in inspector requirements as more power plants reach commercial operating status, and the limited NRC inspector resources, the concept of resident inspection was envisioned as a possible alternative to regionally based inspectors. Potential benefits envisioned from this alternative inspection technique were:

a. Increased Inspector Efficiency: Inspector efficiency was expected to improve because of greater familiarity with plant systems, records, and staff.

b. Increased On-Site Insoection Time: More frequent and less structured plant inspections were expected to increase inspector visibility, both to the licensee and to the public.

c. Increased NRC Awareness: Incteased frequency of visits and inspector freedom were expected to lead to improved licensee compliance and permit more rapid evaluation by th'e inspector of reported events and licensee corrective action.

A trial resident inspection program (RIP) was scoped and defined to i facilitate both objective and subjective evaluations of the potential benefits, and to attempt to consider these benefits against envisioned problems. Costs which were envisioned included:

a. Monetary Costs: Costs associated with reactor office locations and relocation cost were estimated to be significant.

b. Inspector Reauirements: Inherent experience and maturity requisites for resident inspectors could necessarily restrict availability of candidates,

c. Loss of Inspector Objectivity: Closer association for extended periods by the inspector with plant staffs would tend to affect '

the objectivity of the inspector's viewpoint.

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d. Licensee Reaction: Negative licensee :eaction was anticipated as a result of tne increased inspectcr ar>.sence and resultant enforce-ment action.

e. Insoector Acceptar.ce: Availability of 'nspectors was anticipated as a problem aue to the need .for frequent family moves and attendant expenses.

The trial program was structured to incluae two locations (identified as RIP-1 and RIP-2), each ccmprising three power reactors, utilizing an ,

inspection program paralleling the then existing routine operating reactor inspection program. The resident inspector was stat'ioned in an office, external to the power stations, but within short driving distances i of therc.. Supervision was provided from the Regional Office. -

To facilitate measurement of benefits and costs, the trial inspection program was defined for specific areas, and specific evaluation criteria -

were established. The initial program dafinition was formalized by memo- -

randum, 8. H. Grier to J. G. Davis " Resident Inspection Program," dated  %,

March 19, 1974, with attachments.1* The program was scheduled to continue "*

for two years, utilizing two experienced inspectors fr:m the Region III Office. An interim evaluation of the program was performed 2 midway in the trial program, and a final formal evaluation was conducted at the end of the two-year trial program. This report documents the final evaluation .

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conducted at the conclusion of the trial progrcm.

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• Superscripts indicate Section 9 References.

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3. TRIAL PROGRAM DESCRIPTION 3.1 Trial Program Execution The trial inspection program was initiated in June 1974 by stationing the first resident inspector at Two Rivers, Wisconsin, with responsi-bility for inspection of Point Beach Unit No. 1 and Unit No. 2 and Kewaunee facilities. As outlined in the program proposal,1 the primary benefits expected from this trial program were demonstration of increased on-site inspection time, increased NRG awareness of facility activities, and increased inspector efficiency. In addition to the initial location identified as RIP-1, a second trial location identified as RIP-2, was initiated in September 1974 at Benton Harbor, Michigan, with inspection responsibilities for the Palisades and D. C.

Cook facilities. An interim progress evaluation was conducted in February 1975 as documented in a memorandum dated March 10,1975, from J. H. Sniezek to B. H. Grier. Because of the slippage of the E. C. Cook facilities, the RIP-2 location encompassed not only an operating reactor (Palisades), but also a reactor in the test and startup phase (D, C. Cook Unit No.1). The D. C. Cook Unit No. 2 was excluded from the program since it remained in the construction stage during this program period.

The trial evaluation program continued until October 1976, after which a final benefit-cost analysis for the RIP was conducted.

3.2 Evaluation Basis N The initial program descriptioni provided for a status review after six months, an interim evaluation of benefits and costs after approxi-mately one year of the resident inspection program implementation, and a final evaluation after two years. Basis for the benefit-cost analysis was included as Enclosure 3 to the Program Scoping Document dated March 19, 1974.1 Following the six-month review, minor changes in the benefit-cost analysis technique were made3 based on experience at that point in the program and data base availability. The originally defined evaluation technique provided for a Region III and IE:HQ analysis of the effectiveness of the program and impact on regional management.

The RIP-1 site was visited by the evaluation team to perform the interim evaluation on September 18-19, 1975. A similar evaluation visit was made to the RIP-2 site November 20-21, 1975. Observations of the evalua- ,

tion team and their conclusions were incorporated into the report of the interim evaluation.2 {

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Following analysis of the interim program results, the evaluation was finalized.4 Minor changes in the evaluation basis from the interim e'calua-tion were required due to programmatic changes and data base availability.

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The evaluation team conducted the final benefit-cost assessment for the RIP-1 portion of the program during the period August 10-12, 1976, and 1976. for the RIP-2 portion of the program during the period flovember 3-5, Data necessary for manpower utilization evaluation were obtained from the RMS* and 766 data portions of the IE flanagement Information Systems; interviews were conducted with regional st;pervision and the assigned inspectors, D. C. Boyd and K. R. Baker, and opinions were sought from management of the plant superintendents. of the involved utilities, both formally and by interview Inspection program accomplishment was l assessed inspector maintained records. by review of the inspection records, inspection reports, and i.

• RMS - an internal computer maapower record system utilized by the NRC.

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4. TRIAL PROGRAM RESULTS ,

4.1 Accomplishment of the Inspection Program l l

For the purposes of the resident inspection program, a more detailed  :

definition of inspection requirements than normally provided for non-RIP inspectors was provided as Enclosure 2 to the program description.1 This inspection pro 5 ram was implemented at the RIP-1 site for the three reactors in the operating phase. Subsequent to issuance of the program descrip-tion,1 but before the RIP-2 site was activated, a newly defined inspec-tion program was issued for implementation at all other power reactor facili. ties. Since the new inspection progr m was applicable to reactors in the test and startup phase, as well as the operating phase, it was decided that the inspection program. defined in IE Manual Chapter (MC) 2500 would be utilized at RIP-2, and that RIP-1 would change to the ..

new inspection program after one year of the trial program. The RIP-2 inspector therefore accomplished his program in accord with MC-2500 and the RIP-1 inspector changed to the MC-2500 inspection program in July 1975.

a. Background The inspection programs were different at the RIP-1 and RIP-2 sites during the first year of the trial program due to changes in the IE inspection program which occurred in April 1975 com-bined with different operation (1 ~ status of the trial facilities.

At the time of initiation of RIP-1 in July 1974, Point Beach Unit No. 1 and Unit No. 2 had been in operation since December 1970 and May 1972, respectively, and Kewaunee was in final phases ' , ~,

of startup testing having been initially made critical in March 1974. RIP-2 was initiated at D. C. Cook Unit No.1 in August 1974, with the unit in final stages of preoperational testing.

Startup testing commenced in January 1975.

I Palisades was included in the RIP-2 program in January 1975.

Palisades had been in operation since May 1971.

b. First Year of Trial Program _

Evaluation of accomplishment of the first year of the trial i program was difficult because the involved facilities were not in the same phase of operation. Comparison with the routine program was also complicated by a change in Inspectica and i

Enforcement Procedures in April 1975 from Temporary It;struction i

, 1800 to Manual Chapter 2515, which specifically delineated the ,

l required inspection effort. In addition, a special inspection I program had been prescribed for the first year of resident

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inspection of the Poiat Beach and Kewaunee facilities. This '

program was primarily based upon examination of compliance with

• Technical Specification requirements during the year. Review of inspector maintained records for the first year of the trial program established that all facets of the prescribed inspection programs were accomplished at the two sites. During development of the program, it was estimated that the defined inspection requirements would require approximately 100 on-site inspection days by the resident inspector at the two facilities (55% at -

the dual unit plant and 45% at the single unit). Comparison of on-site times with non-resident inspectors performing the routine program at other facilities are detailed in Section 4.2. A pat-tern of inspection evolved at both trial program sites which re-suited in about 145 trips to assigned facilities by each resident inspector during the first year period with an average duration -

per trip of 4.6 and 5.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> respectively.

c. Second Year of Trial Procram ..

The second year of the trial program enabled objective evaluation -

of inspection program accomplishment since the affected facilities ,

were all in routine power operation and were all inspected in accordaoce with Inspection and Enforcement Manual Chapter 2515 requirements. The same inspection requirements also applied to all other operating power reactors. These inspection requirements are divided into approximately'60 individual procedures er modules applicable to operating power reactors. In Region III, 21 of these modules which are required to be perforned annually or quarterly are assigned to the Reactor Operations and Nuclear Support Branch, along with 6 refueling modules and 28 modules _

D which are performed at various times as required or when ap-plicable. The remaining 25 modules are normally inspected by specialists from other Region III inspection branches and con-tinued to be inspected by them under the Trial Program. The average time to complete the 27 periodic and refueling moduits assigned to the Reactor Operations Branch was determined for Region III single unit and cual unit facilities outside the ~

Trial Program (Table 4.1.1). These average values are compared with actual hours required by the resident inspectors to ccmplete each module at their assigned facilities (Table 4.1.2 and 4.1.3).

Modules which were ir.spected by others at the trial facilitics were excluded from this evaluation. The sum of the average values at each trial facility indicate the direct inspection effort (on-site and off-site) which would have been required under the routine program to ccmpleta the same modules.

Inspection data were comoiled in Table 4.1.1 from the data file for the following reactor facilities:

Dual Unit Facilities Sinale Unit Fac;1ities Zion Unit No. 1 and Unit No. 2 LACBWR Quad-Cities Unit No. 1 and Unit No. 2 Monticello Prairie Island Unit No. 1 and Dresden Unit No. 1 Unit No. 2 Big Rock Point Dresden Unit No. 1 and Unit No. 2 Duane Arnold An apparent anomaly, in which more time wes expended on a per r'eactor unit basis for six modules at dual unit facilities than at single unit facilities, is attributed to the small number of facilities sampled plus the relatively large spread in data for the six modules. The average time for performance of modules at the trial facilities and the resultant efficiencies (Tables 4.1.2 and 4.1.3) were not significantly affected by the anomaly.

The data in Tables 4.1.2, 4.1.3, and 4.2.1 were analyzed to determine the degree of inspection program accomplishment by the resident i inspectors relative tn nonresident inspectors. Time per periodic l

inspection module and total onsite inspection time were used to determine quantification of inspection program acccmplishment. Resident inspectors expended more time per inspecti.on module conducted. They were resper.tivel 0.90 and 0.60 as efficient per Onit time in completing inspectior, modules as were nonresident inspectors. However, resident inspectors spent more time engaged in onsite inspection by a factor of 1,49 and 2.02 respectively. The combination of the factors produced an overell gain in program accomplishment of 1.34 and i.21 respecticaly. In-sufficient data were available to compare efficiency of inspection of non-periodic inspection modules. Independent inspection effcet was enhanccd in the trial program in that it constituted 15% of each resident inspector's total effort in contrast to a value of 7% for comparable Region III inspectors in nonresident status.

d. Observations Observations by the evaluation team, based upon review of inspector maintained records included:

-- Because of the frequent site visits, the inspector became familiar with the plant, the administrative systems, and the personnel such that he we.s afforded more freedom within tne plant than a non-resident inspector typically enjoys.

For an ongoing program, this sr.ould improve the effectiveness of the inspector.

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TABl.E 4.1.1 AVERAGE TIME BY REGI0tl III NON-RESIDENT IllSPECTORS

, TO COMPLETE PERIODIC AND REFUELING MODULES (766 -- JANUARY-SEPTEMBER 1976)

TWO UNIT

• SINGLE UNIT FACILITIES FACILITIES MODULE AVERAGE TIME AVERAGE TIME PER UNIT FREQUENCY NUMBER 'SHORT TITLE 4

(HOURS) (HOURS)

A 35701 Quality Assurance 5 13 .

A 36700 Organization & Administration 4 4 A 37700 Design 11 5 A 38700 Procurement 8 4 A 39700 Records 7 4 A 40700 Audits 6 5 A 41700 Training 7 5 A 41701 Requalification 6 5 A 42700 Procedures 11 10 ,

A 42702 Fire Protection 9 6 A 54700 Cleanliness 1 2 [

A 56700 Calibration .

6 7 A 56701 Calibration , 5 7

', R 60705 Preparation for Refueling 9 7 R 60710 Refueling 15 15 A 61700 Surveillance 10 5 A 61701 Surveillance -

A 62700 Maintenance 7 14 R 62701 Refueling Maintenance 5 4 i-Q 71710 Operations 33* 18*

R 71711 Refueling Operations 2 3 R 71712 Refueling Operations 6 3 A 71720 LSSS R 72700 Refueling Startup 16 3 I 8 4 b Q 90710 Operations 12*

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A 90711 Operations 1 1 A 90730 Ar.nual Report 3 1

• for 3 Quarters 9_

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TABLE 4.1.3

- COMPARISON OF ACTUAL TIME BY RIP-2 TNSPECTOR WITH AVERAGE TIME BY OTifER -

REGION III INSPECTORS TO COMPLETE PERIODIC AND REFUELING MODULES (766 DATA -- JANUARY-SEPTEMBER 1976) . ,

Cook Unit 1 Palisades RIP NON-RIP RIP tion-RIP Module ACTUAL / AVERAGE ACTUAL / AVERAGE Frequency flumber Short Title (Hours) (Hours)

A 35701 Quality Assurance 6 / 5 -

A 36700 Organization & Administration 8 / 4 -

A 37700 Design -

8 / 11

-A 38700 Procurement 10 / 8 -

A 3970J Records 8 / 7 6 / 7 A 40700 Audits 36 / 6 -

A 41700 Training - -

A 41701 . Requali fica tion -

8 / 6 A 42700 Procedures 24 / 11 -

A 42702 Fire Protection - -

i A 54700 Cleanliness 6 / 1 10 / 1 A 56700 Calibration ,

16 / 6 -

A 56701 Calibration $ 14 / 5 -

R 60705 Preparation for Refueling - 36 / 9 R 60710 Re fueling - -

12 / 15 A 61700 Surveillance -

16 / 10 A 61701 Surveillance - -

A 62700 Maintenance -

10 / 7 R 62701 Refueling Maintenance -

8 / 5 Q 71710 Opera tions 39 / 33 36 / 33 R 71711 Refueling Operations -

12 / 2 R 71712 Refueling Operatior.s - 5 / 6 A 71720 LSSS 8 / 16 -

R 72700 Refueling Startup - 20 / 8 Q 90710 . Operations 18 / 12 23 / 12 A 90711 Operations - -

A 90730 Annual Report 10 / 3 10 / 3 TOTAL 203 / 117 220 / 135 Average per module 15.62 / 9.00 14.67 / 9.00 Efficiency

• 0.58' O.61 Combined Efficiency 0.60

• Efficiency equals average time per module for NON-RIP Inspector vs. RIP actual time.

. _ . __. _ _ _ _ _ _ _ ___ - = __ -_ - ._ _

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-- The inspector's frequent presence was a constant reminder i to the licensee of regulatory requirements.  !

-- During the test and startup period,.the inspector's frequent contact with the licensee reduced tiRC/ licensee interface problems during the startup program.

4.2 Insoection Manpower Utilization -

Since one of the major benefits from the trial Resident Inspection Pro-  !

gram was expected to be greater on-site inspection effort, daily activ-ity time records were maintained by both inspectors. An evaluation tf these records af ter one year showed tha,t they were consistent with the RMS data records for the RIP inspectors; therefore, daily activity records were discontinued, and RMS records were utilized in this evalu-ation. A comparison between the RIP inspectors and other inspectors was accomplished using RMS data. These data are tabulated in Tables 4.2.1 and 4.2.2. Table 4.2.1 delineates the RIP-1 inspector's time in each of the selected RMS categories. Evaluation of these data against inspector records indicated good agreement overall; however, it was observed during the interim evaluation that no differentiation between in-office inspection time and in-office inquiry followup time was being accomplished by the RIP-1 inspector. This differentiation was made during the subsequent year. The time data for the RIP-1 inspector were somewhat affected byJapproximately three weeks of lost time which resulted from a serious medica,1 situation which the resident inspector experienced early in the RIP trial program; however, this ,

pertubation does not appear to affect the overall conclusions.

Table 4.2.1 also delineates the RIP-2 inspector's time in the same categories. The categories of Travel Time (C00) and Ali Other Time for the RIP-2 inspector were significantly affected by the multiple moves of the RIP-2 field office. Initially, the office was located more conveniently to the D. C. Cook plant and to an all-weather freeway between the two sites such that travel time was minimized.

The final office location was less conveniently located thus resulting in increased travel time to and from the two plant sites. ,

j h

Within the category of All Other Time, the time for the RIF-2 inspector 1 was higher as a direct result of lost time involved in coordination of the office meves and resultant adminictrative burden. A part-time secretary was provided for the RIP-2 office for the second year in an attempt to reduce this time category; however, no significant reduction was evident.

Table 4.2.1 also compares FY 1975 manpower time distribution for the RIP-1 and RIP-2 inspectors with similar time categories for other selected inspectors. For the purpose of this. evaluation, seven L

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additioral Region III inspectors with similar work histories were selected. Their RMS profiles were tabulated in Column 3 of Table 4.2.1.

A selection of RMS data for 27 selected inspectors in all regions with similar work profiles was accumulated and is tabulated in the fourth column of Table 4.2.1. From this table, it' appears tnat:

a. A significant reduction in in-office, docket-related effor.t, other than in-office inspection effort, resulted from the reduced documentation practices for the RIP-1 inspector.

• This reduction was not observed for the RIP-2 inspector since ~

the status and problems of his facilities did not permit the abbreviated method of documentation. ]

b. An increase of approximately 50% in the combined on-site and of f-site inspection effort relative to other typical inspectors apparently resulted from the closer proximity to the facilities and resultant greater flexibility of both of the resident inspectors in scheduling on-site time,

c. On-site inspection effort was increased by greater than 50%

over selected non-RIP inspectors; however, for the RIP-2 inspector, this was only an increase of 28% over this 1974 performance. This is explained in part by the prior assign-meht of the inspector to the Zion facility (preoperational and startup status) which is located within 50 miles of the IE:III office. This benefit appears to be directly attributable to the~ resident inspector concept. .

d. Travel time remained essentially consistent with other categories of inspection. This indicates that a reduction in travel time for the resident inspector was not attained as anticipated.

This unexpected result is due to the application of inspection time employed by both inspectors. They usually spent part of the day on-site and part of the day in the office, with cco-muting time to the sites included in the normal eight hour work day as Travel Time, whereas the other IE inspectors nor- l mally commute to the site during non-regular hours. I

e. A reduction in "all other" type activities was apparent for the RIP-1 inspector. This was because the inspector had not l been assigned additional work activities as he would have l been in a regional office. Consequently, he had devoted essentially all of his time to docket-related activities.

As noted above, the multiple office moves for the RIP-2 in-spector affect these data, and thereby preclude a firm con-clusion.

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For comparison purposes, Table 4.2.2 was developed to show the FY 1974 performance of the resident inspectors relative to the selected Region III inspectors.

It 'is noted that the inspectors were essentially equivalent in all categories to the other inspectors durino the FY-74 period; high however, on-site as previously inspection  ! effort. noted, the RIP-2 inspector had a typically This tends to confirm the observation that significant time benefits to the inspection program have accrued as a result of the location of the inspectors in the proximity of the facilities.

Tables 4.2.3 and 4.2.4 were prepared to evaluate the relative inspection effort for the resident inspectors and the support inspectors (those based in the Regional Offices that performed reactor safety inspections l at the RIP facilities). As shcan, the support inspection effort for i

4 the RIP-1 facilities inspection effort. was roughly equivalent in total to the resident stable operation. This appears reasonable for facilities in relatively On the other hand, for the RIP-2 facilities, the support effort was approximately double the resident effort apparently as a result of the dynamic conditions at these two facilities. (D. C.

Cook Unit No. I was in test and startup for the first year; Palisades was experiencing operational difficulties, primarily with steam generator tube corrosion and with core internals vibration). These data are significant in that they indicate a potential area for furtter benefit from the resident concept if the resident inspector were given responsibility'to perform selected inspections currently assigned by Region III to specialist support inspectors, and to follow-up and closecut inspection findings of the speciA list inspectors.

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TABLE 4.2.1 ,

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MANPOWER TIME

• DISTRIBUTIOll FY 1975 AND 1976' Other Resident Other Inspectors Inspector Region III from Other

' RIP-1 RIP-2 Inspectors Reaions ITO In-office docket-related sfforts 23.9 28.0 33.6

, 31 .9 ITW On-site inspection effort 27.2 36.7 18.2 20.4 ITX Off-site inspection effort includes in-office 22.5 2.5 6.9 7.6 C00 Travel Time 9.2 6.5 8.2 8.0 800 Professional Improvement 4.9 1.6 4.7 7.5 Investigations / Inquiries 0.9 1.4 2.5 2.2 Absence 10'.'8 7.2 11.5 9.3  :

l All Other 0.8 16.1 14.4

! 13.1 Percentage of which was non-regular hou', s 3.5 j

8.0 9.7 12.3 1

• All values are in percent of total time recorded in RMS file I

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1 TABLE 4.2.2 l MANF0WER TIME

• DISTRIBUTION l l

FY 1974 Other Resident Inspector ** Region III RIP-1 RIP-2 Inspectors ITO In-office docket-related efforts 32.6 34.8 35.6 ITW On-site inspection effort 18'.6 28.5 16.7 ITX Off-site inspection effort, including in-office 17.6 6.3 8.0 C00 Travel Time 7.1 9.2 7.1

, B00 Professional Improvement 11.5 6.0 9.0

, Investigations / Inquiries -

1.4 1.1 Absence

.l.0. 4 5.8 10.7 All Other 2.4 8.0 11.7 4 Percentage of which was non-regular 1

hours 10.7 11.3 11.7 1

All values are ir, percent of total time recorded in RMS file Prior to becoming a resident inspector

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TABLE 4.2.3 SUPPORT MANPOWER TIME

• DISTRIBUTION - RIP-1 FY 1975 AND 1976-Point Beach Units 1 and 2 Kewaunee

' Support Resident Support Resident ITO In-office docket-related efforts 825.3 648.5 552.1 372.4 ITW On-site inspection 465'.3 668.5 390.5 537.0 ITX Off-site inspection, including in-of fice 84.0 627.3 162.5 345.3 C00 Travel Time '198.0 140.7 221.7 140.3 Total 1572.6 2085.0 1326.8 1395.0 Total Support 2899.4 Total Resident '3d80.0

• All values are manhours as recorded in the RMS file for reactor safety inspections

4 TABLE 4.2.4 SUPPORT PMPOWER TIME

• DISTRIBUTION - RIP-2 FY 1975 AND 1976 l

l D. C. Cook Unit 1 Palisades **

~ Support Resident Support Resident ITO In-office docket-related efforts 1729.0 612.8 1732.1 510.0 ITW On-site inspection 1025.0 947.4 993.3 489.9 ITX Off-site inspection,

! including in-office 304.0 60.0 81.0 60.3 C00 Travel Time 441.5 48.8 496.3 116.4 i

Total 3499.5 2209.0 3302.7 1185.6 l Total Support 6802.2 Total Resident 3394.6

• All values are manhours as recorded in the RMS file for reactor safety inspections -

• • Assigned to RIP-2 inspector on January 8,1975 i

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d 4.3 Safety of~0perations-l

a. Comoliance History l Evaluation of the safety of operations in a comprehensive sense was not quantitatively assessable. Certain aspects related to safety of operations which could be quantified were included as elements in the previously established guidelines for RIP cost benefit analyses. The significance of these quantified -

results must necessarily be qualified by judgment. Other aspects of safety of operations could not be quantified, and, as such, their treatment has been limited to subjective evalu-ation.

A relative degree of regulatory aw'areness of safety related issues was quantified by comparing the enforcement records of trial program facilities with those of otner licensed l power reactor facilities.

Tabulated in Tables 4.3.1 and 4.3.2 are the enforcement records for the five RIP facilities and five facilities chosen because they were the previous facilities inspected by the assigned RIP inspectors. Data are tabulated in Table 4.3.1 indicating the number of items of noncompliance identified during the year prior to the resident inspection program at the RIP-1 facilities, the number identif.ipd at the inspector's previously assigned facilities during ths year prior to the start of RIP, and the number identified during the two years of RIP at all facilities. Table 4.3.2 presents similar data for RIP-2.

Evaluation of the data from these tables indicates that there has not been a significant change in noncompliance history at these facilities.

Antlysis of contributing factors in the observed levels of noncompliance revealed two countervailing ef fects which could be only evaluated based on judgment. On one hand, increased inspector knowledge and awareness, discussed in Section 4.4, enabled the resident inspector to identify problems which could lead to future noncompliance. In a preventive sense, the resident inspector took initiative to focus licensee manage-ment attention on the potential for noncomplianca that, in the absence of corrective action, may lead to citation. The resident inspectors consMered this preventive appr3ach to be in the best interests of the NRC in enhancing the safety of operation instead of remaining silent until noncompliance had occurred and a citation could be issued. Licensee management prerogatives to effect corrective action in advance were not considered abrogated

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TABLE 4.3.1 RELATIVE ENFORCEMEtlT llISTORY*

RIP-1 Point Beach Point Beach Quad Cities Item Unit 1 Duane Arnold Uni _t 2 Kewaunee Unit 11 Unit 11

c. Number of items of noncompliance identified during year prior to 9 5 25 RIP at RIP facilities (FY 74) l> . ilumber of item.s of noncompliance identified at inspector's pre ~

vious facility during year prior 23 10 i

tc RIP.(FY 74) ru

c. Namber of items of noncompliance J identified during first year of 6 6 18 RIPFY'?S) 18 15

d. Humber of items of noncompliance identified during second year of 10 12 16 RIP (FY 76) 20 492 i

1 RIP-1 inspector's previously assigned facilities.

2 Includes 11 citations developed as part of a special Management Inspection.

4 Enforcement l'istory was obtained from 766 File, and for the purpose of this report, the period August 1 to July 31 for RIP 1 is considered the FY of interest.

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TABLE 4.3.2 RELATIVE ENFORCEMENT HISTORY

• RIP-2 D. C. Cook Point Beach Item Uni t 1 Point Beach Zion Palisades Unit 11 Unit 21 Unit 11

a. Number of items of noncompliance identified during year prior to NA 25 RIP at RIP facilities (FY 74)

b. Number of items of noncompliance identified at inspector's pre-vious facility during year prior 9 5 25 to RIP (FY 74) to

~

c. Number of items of noncompliance

' identified during first year of .

18 3: 34 RIP (FY 75) 9 7 522

d. Number of items of noncompliance identified during second year of 33 11 RIP (FY 76) 13 34 I

RIP-2 inspector's previously assigned facilities.

2 Includes 19 citations developed as part of a special Management Inspection.

• Enforceaent history was obtained from 766 File, and for the purpose of this report the period October 1 to September 30 for RIP-2 is considered the FY of interest.

._...____m.-__.____ '_ _________m.__-_ .__-_____..____-___' _ **t

Evaluation of data for reportable occurrences reported to Region III by the inspectors revealed no significant chcnge in elapsed time between notification from the licensee to notification of regional supervision, including cases having special significance, in which case notification vras essentially immediate.

The remote location of the resident inspector and the attendant higher threshold for communication with his regional superv'ision resulted in the application of inspector judgment as to whether the significance of a particular event warranted an immediate report via telephone and expenditure of NRL resources by regional management.

In cases of special significance, such as the steem generator tube failure at the Point Beach facility, the residen inspector notified his regional supervisor immediately (at approximately 6:00 a.m.), prior to the resident inspector's departure from his nome to the site.

In situations where, based on resident inspector judgment, the reportable occurrence did not warrant immediate notification of regional supervision, the cost of telephonic communication and time expenditure of regional supervision were saved.

Because of the prcxim;ty of the resident inspector, it was observed that: t

-- Reportable occurrences could be m6re rapidly assessed as to significance based on the inspector's independent evaluation, and the inspector could verify the licensee's evaluation, resulting in more meaningful information flow to regional supervision; and

-- Events of special significance, many of which were not [

reportable occurrences, could be more rapidly evaluated j and corrective action verified witnout the problems and

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expense of dispatching an inspector to the site from the Regional Office.  !

j Even though not always required, one of the inspectors (RIP-1) charac-teristicnlly evaluated eil . licensee event reports as soon as ~ practical after initial not1fication, frequently closing out on-site inspectior of these items prior to receipt of the licensee's written report. The other inspector evaluated licensee event reports as reouired by the formal inspection program of IE Manual Chapter 2515, such that no benefit in this crea resulted. (Dur ing the trial program, MC-2515 require:! in-office screening of all reported licensee occurrences

1 and a quarterly selective sample inspection of licensee event reports.) '

Basing the inspector near the site has demonstrated that a potential l benefit in this area can be achieved. This early site evaluation could benefit both the inspector and licensee, since data cculd be I more readily available and time would not have dimmed the memories of the individuals involved. This is identified as a direct benefit l of the RIP concept, both to the NRC and to the licensee.

4.4 Inspector Awareness .

This evaluation parameter was selected ~to identify problems unique to a facility which are identified by the inspector independent of the reporting requirements of the licensee. Examples of items identified ,

by the RIP-1 inspector were: l'

a. Identification of a general problem for torque switch setting and thermal overload protection for limitorque valve operators. l I

b. Identification of the impact of a backlog of administrative '

actisities upon the ability to satisfy regulatory require-ments. i l

c. Identification of a problem not recognized by the licensee with respect to a breaker failure.

d. Identificationandlocationof$ bottomed-outpipehanger.

e. Identification of a rod insertion limit procedural error which resulted in incorrect operator information.

Similar examples of items identified by the RIP-2 inspector were: 1

a. Improper fastening of cable identification tages in the contain-ment ice condenser,

b. Identification of ice condenser anomalies to the Licensing i

Project Manager. j c.

Discovery of a nitrogen bottle in containment, and a valving t

i error prior to the integrated leak rate test.

L d. Preventicn of the licensee's violation of technical speci-i fications regarding nuclear instrumentation operability requirement, liquid radwaste release limits, and flux tilt l

1

. surveillance monitoring.

e. u Identification of an inattentive guard. U 1

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f. Implementation of vital area radiation zone controls.

In addition, because of his familiarity with the facility and his frequent visits, the inspector was able to expedite requested changes to the D. C. Cook Unit No.1 Technical Specifications prior to operating license issuance through direct communication with the assigned Licensing Project Manager. Review of these items by the evaluation team indicated that these types of items are of a nature such that they may normally have been detected or performed by a non-RIP in-spector and their identification and correction prior to their be- -

coming more significant was not necessarily a direct result of the frequent visits and greater inspection freedom afforded the RIP inspector.

Licensee management, regional supervision, and the resident inspectors all agreed that the resident inspector concept did enable the inspector to gain far better knowledge of the physical plant and the licensee  !

organization. Although the specific examples above could not be <

attributed directly to the presence of a resident inspector, the I resident inspector was mere effective in identifying problems such as- I

a. Equipment which is operable, but whose reliability based on i frequency of breakdown may be degraded.  ;

Administrative policies or practices that are or are becoming b.

deficient.

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c. Need for preventive measures (improvement) which if not taken in advance of significant evolution's such as refueling, could result in future mistakes and noncompliance.

This acute knowledge enabled the inspector to channel his empnasis toward problem areas via independent inspection effort.

The resident inspector also knew individual operators and workers better, saw more of what went on day to day, and know how mainte-nance was actually performed. He could get down to the working level and use direct observation with understanding, specific t'echnical knowledge, confidence and respect of licensee personr.el.

Greater inspector awareness is not without potential cost. Without effort to the contrary, the~ resident inspector could become involved in the licensee's decision making process. The assigned inspectors guarded against this tendency by not recommending courses of action, but rather causing the licensee to discharge his responsibility.

Problems identified by the resident inspector were considered by the licensee who based any policy or program charge on his own analysis, not on recommendations of the resident inspector. Circumvention

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of the licensee management because of the increased direct licensee employee contact is a potential cost. On occasion the resident inspector became aware of problems before the plant manager. This i was cause for some measure of licensee embarrassment, but regardless of who notified whom, improvement / correction was considered to be in the public interest and effectively served NRC objectives.

The higher level of inspector awareness and identification of more I problems in case of a recalcitrant licensee was considered to be l

a. factor in greater superviscry effort on the part of regional management. In contrast, generally lower awareness cf the non-RIP inspector in the case of recalcitrant licensees was thought to result'in less supervisory effort expended because fewer problems would have been brought to their attention. Regional supervisory efforts regarding recalcitrant licensees are more closely related 1 to the number of probleins identified than to the resident vs. l regional inspector mode of inspection. l 4.5 Supervisory Effort l An increase in effort was required from the Project Section Chief to supervise the resident inspectors when compared on a per inspector basis with non-resident inspectors. This increase is attributed to reduced conrnunications flexibility and the necessity for cdditional ,

review of inspection results documedation by the Section Chief. A l slight increase in Section Chief travel time in support of the  !

' resident inspectors relative to non-resid'ent inspectors was also '

noted; however, this was not considered a significant increase.

Approximately equal effort was required by the Section Chief to {

supervise the inspection program of five reactor units under the routine program when compared to that required for the five reactor units under the RIP inspectors. Three project inspectors were assigned to perform and manage the inspection program at the five remaining reactor units, whereas two were assigned for the five .

RIP inspected units. l l

The normal span of control for a Projects Section Chief of 5 to 8 )

inspectors should be decreased to a range of from 4 to 6 inspecters  !

under a resident inspection' program due to the increased supervisory l effort required; however, this ruductica in number of inspectors l would be offset by the larger number of ieactor units inspected by i a resident inspector. J J

4.6 Administrative and Support Funj.j; ions Table A.6.1 compares the cost of admiri;trative end supoort functions L for resident inspectors with a wivelent costs for non-resident inspectors.

Review of these daca on a per inspector basis reveals the following l

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TABLE 4.6.1 COST COMPARISONS FOR RESIDENT INSPECTIONS ADMINISTRATIVE AND SUPPORT FUNCTIONS RIP-1 (Boyd)" RIP-2 (Baker) Non-RIP 0FFICE FACILITY AND EQUIPMENT RENTAL J

Facsimile $' 76/ month $ 76/ month $ 1/ month Telephone (facsimile) 55/ month 32/ month 30/ month Telephone (verbal) 101/ month 161/ month --

Copy Service 30/ month 60/ month 25/ month Secretarial Service (1 day / week) 125/ month --

Message Recorder (initial one-time cost of purchase 9/ month 11/ month --

amortized over 2 years)

Office Space 12 / month 265/ month 80/ month Total Office Costs / Month 396/ month 730/ month 136/ month Total Office Costs / Year 4752/ Year 8760/ Year 1632/ Year TRAVEL COSTS Travel Cost / Inspector 1397.76 1383.24 3704.11 MOVE EXPENSES Inspector Relocation Costs 5551.00 5008.00 --

(to RIP site)

Office Relocation (to RIP) 250.00 290.00 --

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Office facility and equipment rental costs exceeded the normal cost of effice provisions by from $3120 (RIP-1) to $7120 (RIP-2) per year.

b. Travel costs for each resident inspect 6r were less than the ,

average travel cost per routine program inspector by approximately l

$2130 per year.

3

c. Reimbursed moving expenses for the resident inspectors averaged

$5300 each move. Assuming reassignment every two years the annual cost due to moving would be approximately $5000 to $6000 per year per RIP inspection assignment.

d. The cost of moving-the resident inspection office facilities averaged 5270 and if amortized over two years results in an annual added expense of $135. This cost would be a or.e-time cost for each new RIP location.

Based on the above the net annual increased cost of maintaining a resident inspector compared to an inspector working out of the regional office could be expected to be approximately $8000 per inspector per year. Actual costs incurred above regional office based inspectors were $6245 (RIP-1) and $10,253 (RIP-2). The major variable was cost of office rental and the use of part time secretarial help. It should be noted that the h.igher. office rental rate for RIP-2 was associated with a federal build'ini which means the actual cost was from the NRC to GSA, i.e., intragovernmental.

The drawback to this apparent advantage was the requirement by GSA to utilize this vacant federal office even though it was less efficient for the resident inspecto.r than available privately owned office space.

A cost effectiveness comparison can be drawn between a resident inspector -

and the average of the non-resident inspector by applying the increases in program accomplishment (Section 4.1) to the above net costs associated with resident inspection. Assuming an annual salary of $30,000 per  ;

{

year for both resident and comparable non-resident inspectors, the net  !

costs associated with the trial resident inspection program are cancelled j by the observed increase in inspection program accomplishments. Within  :

the accuracy of the assumptions and geographic regional cost differences, l resident inspection caused no budget impact additional to non-resident +

inspection.

1 4.7 Qualitative Judaments .

As part of the overall evaluation process, qualitative judgments on the part of the two inspectors' involved in the trial program were

' expressed as indicated below:

a. Maintenance of Insoector Objectivity: Though difficult to assess from tne inspectors' viewpoint, it was their mutual judgment that location in the proximity of the facilities does not reduce the objectivity of the inspector if he is aware of the problem and is constantly' attentive to potential conflicts in this area. Review by the RIP evaluation team, and regional supervision assessment, indicated that there was no indication of loss of inspector objectivity for either inspector. '

b Licensee Coooeration: The inspectors' assessment of the relation-ship with the licensee was that these relationships were sig-nificantly improved by the frequency of the inspection visits.

Additional information is provided in Section 5.

c. Knowledge of Facility Ooerations and Management Policies: A benefit f rom the more frequent visits to tne site was the resultant increase in knowledge of the facility, its operations, 2 and its management team and policies. This apparent increase in knowledge level was obvious to the evaluation team and resulted, based upon the inspectors' analysis, in an increased capability for completion of the inspection program and in a better under-standing of the areas inspected. This aspect alone probably accounts for a majority of the benefit identified in Section 4.1.

d. Impact on Licensee Performance >c The more constant attention of the inspectors to the plant problems resulted in a significant improvement in all licensees' attent'iveness to regulatory require-ments. This may be related to the " cop on the beat" approach to law enforcement, in that the visibility and constant association with the operating personnel resulted in greater and more constant attention being paid to regulatory requirements.

e. Impact on Public Relations in Area of the Plant: An initially surprising result of this program was the very Icw level of  !

public reaction to the stationing of a resident inspector. '

Essentially, no media or public contact resulted from location of the inspector near the facilities during the first year.

During the interval when the RIP-2 field office was located in a highly visible location in a shopping center, several

" drop-in" visits occurred, and in one case a potentidl lend (

i buyer inquired as to the environmental effects near the D. C. 1 Cook plant. After the office was moved to its current location in Benton Harbor Federal Building (a former inner city post ]

office), these contacts: ceased. During the second year there j were several local citi:en contacts and contacts by the press related to plant events. This upturn in local interest may .

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1 be unique; however, it is the opinion of the inspectors and the evaluation team that continuation of the inspector's presence within easy local media access could offer a long range benefit.

No conclusion regarding the local publi.c impact can logically be drawn from results observed during this trial program except that there has not been a strong reaction by the public to the stationing of inspectors near the site.

4.8 Impact on Inspectors The participation in the resident inspection program was evaluated in terms of impact professionally, personally, and financially. Specific benefits and disadvantages are tabulated under the three areas,

a. Professional Impact

1. Benefits (a) Excellent learning opportunity. Increased on-site inspection time with emphasis on observation of operations facilitate greater knowledge of assigned facility.

(b) Increased degree of independence. Reduced direct supervision provided opportunity for increased initiative by the inspsctors and increased authority and responsibility. -

(c) Greater efficiency due to fewer distractions and interruptions. The improvement in efficiency was shown by increased inspection time.

(d) Greater job satisfaction. The inspectors stated that the greater degree of independence and improved continuity resulted in greater job satisfaction.

(e) Improved continuity in inspection activities. The inspector conducted approximately one half of all inspections at the assigned facilities which was an increase of approximately 25% compared to the non-resident progra 1.

2. - Disadvantaces

. (a) Recuced participation in regional training. The resident inspectors were unable to attend formal end informcl trainiro sessions which averaged onco t

S per week. Monthly trips to the region were generally scheduled to coincide with a training opportunity.

(b) Reduced opportunity to exchange views with other inspectors. This was rated as one of the strongest disadvantages by both resident inspectors. Although frequent telephone discussions were held they are not considered to be equivalent to direct discussions.

(c) Unavailable for promotion during tour of duty. This was necessary for the trial program and it is anticipated that a similar arrangement would be required for a routine application of the Resident Program.

(d) Difficulty remaining current with Commission and industry developments. This was a direct result of reduced direct contact with regional personnel and inability to attend regional training.

b. Personcl Imoact

1. Benefits  !

(a) Less time away from home on travel. The resident inspectors spent only 12 nights away from home per year compared with an estimated 40 or more for inspectors working out of the Regional Office. "

(b) Outdoor recreational activities more convenient due to rural lccation. Accessibility to hunting and fishing facilities constituted this advantage.

(c) Small town atmosphere more friendly. This was a marginal benefit in view of restrictions on social contacts deemed necessary .to avoid possible conflict of interest.

2. Disadvantaaes (a) Family dissatisfaction with frequent moves. Frequent moves disrupted schooling of children, circle of acquaintances and friendships for family.

(b) Reduced availability of convenient metropolitan shopping and entertainment. The inspectors found that especially true for major applicances and pro-cessed foods.

u._

(c) Restriction on social contacts due to potential con-flict of interest. In a small community, the necessary restriction of social activities with licensee personnel restricted the circle of friendship which may have other-wise developed.

c. ~ Financial Impact

1. Benefi ts

~(a) Reimbursed moving and sale of home expenses averaged

$5300 each move (Section 4.6). I (b) Certain aspects of cost of living lower in rural area.

Specifically, housing and fresh locally grown produce were generally lower priced. Housirig was estimated to be 10% to 20% less expensive than in the Chicago area.

(c) Reduced travel or commuting cost. A reduction here was dependent upon location of the resident inspector's office. One inspector had ar. increase in commuting cost, the other a decrease.

2. Disadvantages

.c (a) Household goods moving expenses not fully reimbursed.

Both inspectors had household goods in excess of 11,000 lb. limit resulting in unreimbursed expenses of approximately $360 per move.

(b) Cost of new'home loan not paid such as mortgage points and service fees. Non reimbursed new home expenses I ranged from $400 to $700 per move.

(c) Capital gains tax on sale of home (state and federal).

This expense occurred in moving one way from a higher to a lower housing cost area since the inspectors believed purchase of a more expensive home in the lower cost area would tend to rake the house more difficult to resell. The capital gains taxes were expected to amount to $2000.

(d) Delays in receipt of reimbursement of moving expenses.

Reimbursement for house sale related expenses amounting to approximately $4000 required four months, representing a loss of approximately $100 of interest.

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'l i It should be noted that the specified disadvantages are not unique to the resident program but are experienced with most relocations. The disadvantages would be amplified due to the more frequent relocations associated with a resident inspection program. -

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5. LICENSEE REACTION i

As part of the evaluation effort, the evaluation team met with each l

plant superintendent for the RIP facilities and discussed the program 1 and its oenefits and costs from their standpoint. In all four cases, the plant management expressed strong support for the resident concept since it has resulted in a reduced impact upon their operating staff. l This reduction in licensee time requirements has resulted from increased '

mutual respect and professionalism of the inspector and licensee per-  ;

sonnel, more knowledge of the facility and its records by the inspector, and increased trust in the inspector by licensee management. Two of the  ;

licensees did voice concern that an expected reduction in the overall l support inspection effort had not been realized. l 1

All four licensees indicated that the frequency of visits to the site j appeared adequate to maintain cognizance of the facility operating status. In addition, they stated that the inspector frequently called i l

the site to_ escertain plant status and problems on days when he was not planning to be on-site. The RIP-1 facility management indicated their {

l support for the immediate followup activities of the inspector as related to reportable event situations such that data retrieval and )

licensee manpower requirements were minimized. Three of the four i

facility managers indicated their confidence in the inspector and their  !

desire to maintain him continually aware of plant problems, thereby facilitating incorporation of any unanticipated regulatory requirements

' into their evaluations and plans. -The fourth had not developed a strong position in this regard, but was not negative. The inspector's familiar-ity with the record system and increased licensee trust made it possible for the inspector to obtain data and records without plant staff support. l In one case, a plant superintendent indicated that the objectivity and  !

independence of the inspector, rather than being reduced, may actually have been enhanced by his greater plant familiarity, since he did not depend as greatly upon the spoken statements of plant staff, but rather could more directly assess conditions independently following reportable events. This observation, taken in conjanction with regional super- i l

vision's increased confidence in inspector-supplied information, tnds  !

to offset concerns about potential loss of objectivity due to over-familiarity of the inspector with a facility and its staff. One licensee  !

representative noted that any apparent loss of objectivity by an inspector  ;

could not be tolerated by the licensee due to the potential for publicity adverse to the utility. He indicated his opinion that a responsible i licensee would request reassignment of an inspector, if the inspector's i independent viewpoint were ccaromised, i 1

' Initial concern by all four plant superintendents relative to the greater intensity of inspection effort es totally allayed by the experience  !

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during the two years of plant operation under the RIP concept. None of the plant superintendents identified any deleterious aspects of the rip from their viewpoint. All did, however, voice the strong opinion that careful selection of inspectors would be required to ,

assure maturity, inspection experience, and operating experience, i since greater reliance is placed upon the independent judgment of this j inspector. This observation vas iterated by regional . supervision.

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, 6. RELATED EXPERIENCE As outlined in the evaluation program,2 i t was desired to compare the Canadian inspection processes with the U. S. inspection process. This comparison was accomplished by a visit / umented in Reference 5, which relates the observations of a portion c. the evaluation team following their visit to the Atomic Energy Control Board of Canada (AECB). The Canadian inspection program is headquartered in Ottawa, Ontario, and at the time of the meeting had four resident inspectors stationed at two stations. Observations of the evaluation team members concerning the experience of the Canadians were consistent with the observations from the trial program, i i I

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7.

SUMMARY

AND CONCLUSIONS The trial resident inspection program was conducted as described in 4

Section 3 during the two-year period ending July 1, 1976, at RIP-1, and October 1, 1976, at RIP-2. Summarized below are the benefits and  !

costs of application of the resident concept as an alternative to the regional concept. Inherent within these observations, resultant con-clusions and recommendations is the assumption that Regional Offices would continue to exist, and that specialist support from the Regional Offices would be available to supplement the inspection activities of the resident inspector. Identified benefits and costs reflect not only the quantitative measurements of variables monitored during the trial program, but also include cbservations and conclusions of the evaluation ,

team developed through observations, interviews, and supervisory judgment. '

7.1 Benefits '

a. Inspector Utilization: Evaluation of relative inspection effort as reasured by inspection module accomplishmcat has shown that the resident inspector pe-formed 25% more inspection modules than ocaer equivalent Region III inspectors. (Section 4.1)

b. Increased On-Site Inspection Time: Evaluation of records indicates that both resident inspectors were on-site at least

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50% more than equivalent inspectors both in Region III and in the balance of the regions. Ih addition to the increased total site time, more frequent visits have permitted better time utilization by the inspector and a more frequent assessment of plant status. (Section 4.2)

c. Increased NRC Awareness: Discussions between the evaluation team and the regional supervision revealed that the resident inspectors' presence enhanced NRC knowledge of plant status and problems, and permitted a reduced threshold for inspector response to plant problems. Followup and resolution of identified oroblems were also enhanced by the proximity of the inspector. Office of Inspec-tion and Enforcement (IE) supervisory judgments in this area were reinforced by similar observations by facility management.

(Sections 4.4 and 5)

d. Improved Insoector Knowledge: Inspector knowledge of the plants being inspected, including their operating systems and character-istics, their management, the management systems, and the records systems was determined to be significantly improved over typical

' non-resident inspectors based en observations by the evaluation team members. (Section 4.7)  ;

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e. Insoector Acceotance by Licensee: Licensee acceptance of the presence of the inspector was observed to have been significantly enhanced by the development of confidence, mutual respect, and rapport between the licensee and the inspectors. This resulted in easier access to facility records hnd more independence of inspection effort. (Section 5) ,

f. Licensee Time: Facility management stated that a reduction in plant staff support required to support the IE inspector during conduct of inspections was a direct result of the increased knowledge of the resident inspector regarding the facility and its administrative practices. (Section 5)

g. Management Control: Both resident inspectors observed that due to the more constant association with the plant staff, greater emphasis was generally provided to regulatory requirements as expressed in administrative procedures and controls for plant operation. It was noted that the compliance history had not reflected the chance. (Section 4.7) 3

h. Surveillance: -Increased direct observation by the resident inspector was facilitated by greater time availability and access to the plant as indicated by inspector interview and by review of trial program rccords. (Section 4.2)

i. In-Office Inscection: As a result of being located closer to the facility site, the capability to borrow plant records for inde-pendent and more effective review within the RIP office was enhanced. This capability was primarily utilized by the RIP-1 inspector, but not by the RIP-2 inspector. This added flexibility is not necessarily a benefit since it tends to reduce the visi-bility of the inspector, even though it may increase his work capability; however, if properly balanced with on-site time, greater work output could result. Therefore, this flexibility is identified as a benefit for the purpose of this report. (Section 4.2)

'j . _ Inspector Convenience: As a result of location of the duty station near the facilities being inspected, travel time away from home and family was significantly reduced. The inspector's time-in-travel status away from his family was less than 10% as compared with 25-30% for typical inspectors. (Section 4.8)

k. Public Reaction: Though initial public response to stationing -

of the resiaent inspectors was minimal, recent experience at both RIP-1 and RIP-2 have indicated some degree of media and public awareness of the resident inspectors. Both inspectors have been involved in media reports concerning their assigned facilities.

(Section4.7)

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7.2 Costs

a. Monetary Costs: The NRC non-salary expenditures for the RIP trial pro;, ram were approximately $8,000 per rip site per year.

Added expenditures were primarily a result of increased adminis-trative costs and costs associated with inspector relocation.

Adjustement to these expenses for increased site time attained and higher productivity in it.spection program accomplishment reduced the cost differential to insignificance, less than -

$150 per RIP site per year. (Section 4.6)

b. Monetary Cost to Insoector: Costs incurred by the inspectors

.which were not reimbursable under current travel regulations (relocation reimbursement) and income tax laws resulted in unreimbursed costs of approximately $3,000 each over a two-year period. This represents approximately 5% of salary. (Section 4.8)

c. Training: Both formal and informal training of the inspectors by the Region have suffered because of their remote locations.

This cost was partially offset by improved inspector knowledge of his assigned facilities. The inspectors visited the Regional Office approximately once per month, coordinating these meetings with planned training programs; however, informal exchange with other inspectors and with supervision did not occur on the frequency that would prevail if the inspectors were based in the Regional Office. (Section 4 8)

d. Comnunications: Regional Office cdmmunications with the inspectors were reduced as a result of the remote locations.

Nonetheless, the communications from the inspectors to the . . _

Region were more timely and knowledgeable, thereby partially offsetting this potential cost. (Section 4.3) 7.3 Ccnclusions_ l Based upcn the results of the evaluation, the following conclusiens have i been reached by the evaluation team: '

a. The concept cf resident inspection applied to this trial program is viable and preferred for certain reactor safety-type inspections.

and feasible for application under tne direction of regional manage- l ment.

l b. Application of the concept appeers to be restricted by the limiteo t

availability of suitably quclified inspectors, and candidate locations.

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c. Ai improvement in inspector utilization has been quantitatively l

measured. In applications where this increase could be effec- .

tively utilized, increased monetary costs could be precluded. ,

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d. An improvement in licensee compliance' attitudes has been quali-tatively observed at all but one licensee. At that licensee, an improvement in defintion by IE of the causes of noncompliance has resulted in enforcement meetings with the licensee. No change in noncompliance frequency was observed at any of the RIP facilities which could be attributed to the RIP.

e. All participating power plant managers observed that a resident

. inspector concept appeared to be an effective method for NRC-implementation of its inspection responsibilities. They preferred the resident concept over the normal mode of periodic inspections; however, all emphasized the importance of careful selection of suitably qualified inspectors.

f. No tangible evidence or other indication of loss of inspector 4 objectivity was identified during the trial program.

g. Additional exoenditures due to the trial program were offset by increased productivity of the resident inspectors,

h. Significant monetary costs to the inspectors were nonreimbursable within existing regulations pertaining to relocation. These costs, coupled with the expected relu'dt'a nce of employees to relocate to and from resident locations on a three-year interval, could l

restrict the availability of otherwise qualified personnel.

i. Because of the more constant interface with the licensee personnel, the greater reliance placed on the inspector's judgment, his remote location, and increased requirements on inspector integrity, the inspectors must be very carefully chosen to assure their maturity, I experience, integrity, and dedication. The greater demands on l resident inspectors relative to nonresident inspectcrs were considered I to be compensated for by professional and personal benefits realized j by the resident inspectors.  !

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j. Qualitatively, significantly higher knowledge levels of the inspectors l concerning the facilities, their management, and the administrativa l practices were attributed to the lesident inspector environment. l l

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8. RECOMMENDATIONS Based on the conclusions and observations of the evaluation team, the following recommendations are proffered. These have been categorized as direct, i.e., recommendations specific to the objectives of the trial program, and related, i.e., recommendations developed as a side benefit of conducting this trial program.

1 8.1 Direct Recommendations

a. Predicated upon the availability of suitably qualified and

, experienced inspectors, the resident inspection concept is recommended as a means of inspection in the following specific applications in which the benefit to the NRC should be signi-ficant:

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-- A cluster of three or more operating reactor units within a radius of approximately 25 miles.

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-- A single or multi-unit facility during the preop /startup phase (one year before licensing to one year after license issuance).

-- A single or multi-unit operating facility which is considered by IE to be a poor perform.er with regard to compliance with regulatory requirements or 'one whose management is considered to be recalcitrant. .

b. The inspection program currently being conducted at power reactor facilities should form the basis for resident inspection. Minor  !

modifications to current inspection requirements should be initiated in order to maximize the potential benefits of resident inspection.

Examples include greater freedon for random observation, defined re-quirements for "backshift" inspections, increased sample sizes for specified inspections, and more specific guidance for inspection of corrective actions taken by the licensee following reportable events. ,

Additionally, the scope of activity shculd be broadened to include l certain inspection activities currently performed by specialist inspectorj l

c. Criteria and proceiures for program audit and resident insr,ector evaluation shculd be develeped contingent upon future implementation of resident inspection.

d. Resident inspector tours should be for pre-established and finite tinies, probably not to exceed three years. i l

e. Because of the remota locations, care must be exercised ir. the selection of resident inspectors _ to assure their experience, maturity, and dedica tior..

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f. Professional development and career planning should be conducted for IE personnel and should incorporate the resident inspector.

Consideration should be given to developing specific commitments, '

assurances, or preference for post-resident inspector assignments regarding location and position.

g. Arrangements which would provide total compensation of all. moving and real estate costs related to resident inspection assignments should be considered as alternatives to current practices. This is one aspect cf incentives that may be necessary for otherwise qualified inspectors. Arrangements similar to some industrv l

. practices may appear reasonable. l l

8.2 Related Recommendations

a. Region III staff should develop and publish a procedure based on their experience for establishment, support, and closecut of i resident offices,

b. The RIP environment, including expert resident inspector j knowledge of plant and licensee, provides fertile opportunity for training of new inspectors. This opportunity exists particu-  ;

larly during test and startup phases during which time orientation  ;

could be very rapid. This is seen as a complement to existing l technical training programs wijhin IE, rather than as a substitute.

c. Review of conclusions drawn from tl'is trial program reveals that f the conccpt's viability is not dependent upon the status of the facility being inspected, i.e., the concept appears equally feasible for application during the construction, test and startup, and operating phases. The following variations of the trial program are recommended: 1 1

-- A limited program for resident inspection of facilities under construction should be initiated in more than one liRC Region.

As with resident inspection of operating reactor facilities, this wculd facilitata increased direct observation of activities in progress, increased inspector visibility anc availability to craft workers, which are deemed important byproducts of resident ,

inspection. The logistics, management and administrative l practices, which evolveo from the trial program at operating '

facilities, should be directly applicable. l 1

! -- Clusters or combinations of units described in Saction 8.1 above could warrant application of two or mon: resident ins; actors which would facilitate training of a lesser exoerienced inspector by a more experiencsd inspector. The Canadian experience indiccte i

this type of 'nspe:tico program reduces 5

certain dr awbacks ot the l~ resident program througl asrignment of more than ona inspector to one office.

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9. REFERENCES 1

Memo from B. H. Grier to J. G. Davis (

Subject:

Resident Inspection Program), dated 3/19/74, with attachments.

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" Trial Resident Inspection Program Report of Interim Benefit-Cost Evaluation," R. E. Hall and E. L. Jordan, dated 2/76.

3 Memo from B. H. Grier to J. G. Davis, et al (

Subject:

Resident Inspection Program), dated 8/1/75.

4 Memo from J. H. Sniezek to S. H. Grier (

Subject:

Benefit-Cost Analysis for Pilot Resident Inspection Program), dated 7/27/76.

5 Memo from R. E. Hall and E. L. Jordan to G. Fiorelli and J. H. Sniezek (

Subject:

Trip Report - Canadian Resident inspection Program), dated 10/7/75.

A Letter from E. W. James, Wisconsin Public Service Company, to J. G. Keppler, Director, NRC Region III, dated 7/16/76, comment-ing on Resident Inspection' Program at Kewaunee.

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ENCLOSURE 2 CANDIDATE SITES - AS OF GCTOBER 1977

1. Cluster of three or more operating reactor units within a radius of approximately 25 miles:

Browns Ferry 1, 2, 3 '

Dresden 1, 2, 3 Indian Point 1, 2, 3 ,

Oconee 1, 2, 3 Point Beach 1 and 2/Kewaunee D. C. Cook 1 and 2/ Palisades

2. Reactor units entering preoperational , test and startup sequence:

Zimmer i Hatch 2 Sequoyah 2 Summer 1 La Salle 1 Shoreham Salem 2 4.

McGuire 2 .

Watts Bar 1 1

)

Farley 2 i Grand Gulf 1

3. Candidate reactor units under construction:

Bellefonte 1 and 2 Braidwood 1 and 2  !

Byron 1 and 2 I Callaway 1 and 2 Catawba 1 and 2

• 1 Cherokee 1 and 2 Clinton 1 and 2

, -1 ENCLOSURE 2  !

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. . .. 1 Comanche Peak 1 ar.d 2 Grand Gulf I and 2 l

Hartsville 1, 2, 3, 4 Hope Creek 1 and 2 '

1 La Salle 1 and 2 Limerick 1 and 2 '

Midland I and 2 l

florth Anna 2, 3, 4 I Palo Verde 1, 2, 3 Perry 1 and 2 i San Onofre 2 and 3 Seabrook ~1 and 2 South Texas 1 and 2 Susquehanna 1 and 2 Watts Bar 1 and 2 WPPSS 1, 2, 4

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