ML20151H781

Discusses IE Plan for Assessment of Regional Implementation of IE Programs,Based on 820706-07 Meeting in Region Iii. IE Office Procedure on Conduct of Regional Assessment Revised.Cooperation in Efforts Requested

ML20151H781
Person / Time
Issue date:	08/23/1982
From:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Haynes R, James Keppler, James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20151H783	List: IA-87-868, Forwards Region IV Program Ofc Assessment Provided to EDO in Response to 860421 Request ML20151H781 ML20151H804 ML20154A152 ML20154A196 ML20154A226 ML20154A242 ML20154A256 ML20154A283 ML20154A293 ML20154A297
References
FOIA-87-868 NUDOCS 8305090714
Download: ML20151H781 (45)

Text

.

W UNITED STATES j

!( n NUCLEAR REGULATORY COMMISSION h WASHING TON, D. C. 20S66 h%) i

^

R+....} AUG 2 31982 -

MEMORANDUM FOR: Ronald Haynes, Regional Administrator, RI James O'Reilly, Regional Administrator, RII James Keppler, Regional Administrator, RIII John Collins, Regional Administrator, RIV Robert Engelken, Regional Administrator, RV FROM: Richard f., DeYoung, Director Office r/ inspection and Enforcement

SUBJECT:

IE PL/A FOR ASSESSMENT OF REGIONAL IMPLEMENTATION OF IE PROGRAMS Based on our discust fons during our meeting in Region III on July 6-7, 1982, we have revised the, IE Office Procedure on conduct of regional _ assessment and have developed our first IE plan for assessment. Copies of the IE Office Procedure 0200, Assessment of Regional Implementation and the IE plan for regional assessment are enclosed. The assessment plan covers the period August 1982 to June 1983.

The IE assessment efforts will address selected inspection procedures and programs for operating power reactors, construction sites (CAT only),

vendors, fuel facilities, materials, SNM in transit, incident response ,

capabil tty, and enforcement. The asaer.sment will include in-office review of program documentation (correspondence and reports) and 766 and MPS data, supplemented with travel to licensees' sites to observe inspection practices and to the Regional Offices to discuss assessment findings. The IE independent inspection effort (for this assessment year) will be limited to the PAT and CAT inspection activities at reactor sites.

Many of the specif te details of the assessment plans, such as actual sites to be visited, dates of travel, and assessment team members are yet to be finalized. This information will be provided at a later data. However, the enclosed assessment plan does identify the specific programs and program areas to be assessed and the time frame for each of the assessment activities.

We have attempted to estimate the resource impact of our assessment plan on the Regions by estimating the effort that may be required by regional inspectors, resident inspectors, and regional management. The estimates do not include foT4 f 6 f l

h

- _l . . . __ _ _ _

Pegional Administrators AUG 2 3 W effort associated with the PAT and CAT programs. Our estimates are provided below and represent a cumulative inpact for all five regions con 6ined:

A. Reactor Programs 0.6 staff years B. Emergency Preparedness Programs 0.2 staff years C. Fuel Facilities and Materials Programs 0.1 staff years D. Vendor Program (Region IV only) 0.1 staff years E. Enforcement Program 0.1 staff years 1.1 staff years for all five Regions The structured IE assessment of the Regional Offices is a new program. As ,

we begin to implement the assessment plan, some situations may'arise that we had not envisioned. I ask for your and your staff's cooperation in this effort. If you have any questions on the procedure or our assessment plan, please call me, Jim Sniezek or Bill Brach (492-4932) who is the staff contact for the IE assessment plan.

g W ,j RichardC.Deoufg,Direttor Office of Inspytion and' Enforce: rent

Enclosures:

1. IE Office Procedure 0200

2. IE Plan for Regional Assessment ec: W. J. Dircks. E00

v. Stello, DEDROGR IE Division Directors J. Liebennan, OIE d C J. Blaha, OIE C. Kime, 0!E A. Burda, OIE E. Greher, O!E E. Brach, O!E

_ . ~ - _

1 UNITED STATES

' /p* *'%~\

NUCLEAR REGULATORY COMMISSION

( wAsmwoTow, o.c. 20ess oP Fict oF inspecnow Ano IE OFFICE PROCEDURE 0200 ASSESSMENT OF REGIONAL IMPLEMENTATION 0200-01 PURPOSE This procedure explains the approach and metnods used to assess the NRC Regional Office implementation of the inspection and enforcement program.

As u;ed in this procedure, program assessment is an ongoing and systematic process of gathering relevant information and evaluating that information against appropriate criteria to arrive at an informed judgment of whether the program is being carried out in an acceptable manner.

0200-02 CBJECTI %

The objective of program assessment is to periodically provide management with information on the degree of program completion, of the adequacy of program inplementation, and of the consistency of implementation of the program both within and among the five NRC Regional Offices.

0200-03 DEFINITIONS 031 Staff Audit. An ongoing, systematic check, review, and evaluation of documentation, correspondence, and statistical inspection data pertaining to the Regional Office implementation of the inspection and enforcement program. Staff audits are conducted in the IE office with frequent telephone contact with the Regional Offices, as apprcpriate.

! 032 Arsessment Trip. Travel by IE staff to accompany inspectors and ob-

~ serve inspection practices during the conduct of selected inspection procedures. Travel by IE staff to NRC Regional Offices to discuss specific observations, to verify findings, and to discuss Regional comments and response. Travel by IE staff to licensee sites to irdependently verify inspection findings.

033 Program or Program Area Assessment Report,

a. The as'sessment report is a documented evaluation of the manner in which the inspection and enforcement program is implemented for each program or program area selected for assessment. The assessment report is based upon the findings and conclusions obtained through staff audits and assessment trips for each program or program area selected for assessment.

Issue Date: 9/1/82

i 0200-033b ASSESSMENT OF REGIONAL IMPLEMENTATION 4

. l

b. There are two types of assessment reports: (1) a Regional i Report which is preparad for each Region upon completion of assessment activities for a selected program or program area  !

for that Region, and (2) a Summary Report which provides an overview of the assessment results for a selected program and/

or program area for all five Regions. The Regional Reports j will be attached to the Summary Report to provide backup and details.

c. Regional Reports are provided to each Regional Administrator from the responsible Division Director through the Director, IE. Summary Reports are provided to the Regional Admini-strators wi*,h a copy to the EDO, from the Director, IE. '

i 034 Program. A defined program in the IE Manual. The programs are as follous:

a. Reactor Inspection Program (IE Manual Chapter 2500).

b. Fuel Cycle Facility Inspection Program (IE Manual Chapter G00). -

i

, c. Licensee Contractor and Vendor Inspection Program (IE Manual I Chapter 2700).

d. Materials Inspection Program (IE Manual Chapter 2800),

e. Enforcement Program (IE Manual Chapter 0400 in revised Table of Contents, old number 0800). i i

035 Program Area. Sets of inspection activities characterized by similarities of disciplines involved and activities performed. I

' For purposes of this procedure, a program area may be identified as a single IE Manual directive or a group of related directives.

l Examplea of program areas are criticality safety or refuelling at

, operating reactors, welding at reactors under construction, or material control and accounting at fuel facilities, i

0200-04 RESPONSIBILITIES AND AUTHORITIES N1 Director, Of fice of Inspection and Enforcement

l 4

a. approves policies, criteria and standards for assessment of i

program implementation by the NRC Regional Offices.

b. based upon recommendations from IE Oivision Directors, approves  !

l the specific program and/or program areas for the annual IE l program assessment. '

! c. coordinates and approves the scheduling of assessment activities i

for each program and program area selected for assessment. ,

i l d. approves all assessment reports (Regional and Summary Reports).

Issue Date: 9/1/82 --- . _ _ - . - - _ _ . . . _ - - - . _ - - . - - _ - _ - . -

, ASSESSMENT OF REGIONAL IMPLEMENTATION 0200-042 042 Director of Division of Reactor programs, Director of Division of Fuel, Materials and Safeguards, Director of Division of Emergency Preparedness, Director of Division of Engineerina and Quality Assurance, and Director of Enforcement Staf f: ~

a. recommend specific program and/or program areas for the annual IE program assessment to Office Director, IE.

b. serve as IE manager for program assessment activities within assigned program areas or as designated by Director, IE.

c. designate supervisor or senior staff member as IE staff pro-ject leader to plan and carry out program assessment activities for selected program areas;

d. coordinate the scheduling of assessment activities including trips to Regional Offices and licensee facilities and prepara-tion of reports with the Director, IE.

e. coordinate the preparation of assessment reports for each pro-gram or program area selected for assessment.

0200-05 PROGRAM ASSESS'4ENT SYSTEM 051 Cgncapt Progra.1 assessment is a planned process conducted during a twelve-month cycle which begins July 1 and ends June 30. The program areas to be assessed during the assessment year are recoraended to the Director, IE, by es:n Division ar.d Staff Director. The n uber of program areas selected may vary from year to year and some program areas may be selected more frequently than others. It is anticipated that only a few program areas will be selected for assessment each year. It is also anticipated that the schedule for assessment of the selected program areas will be staggered such that assessment activities and reports will be completed through-out the assessment cycle and that there will be no bunching or grouping of activities on individual Regions or during the end of the assessment cycle in Ju....

The Division and Staff Directors will prepare assessment plans for each of their selected program areas and forward the assessment plans to the Director, IE. The Office of the Director, IE, will then prepare the overall IE assessment plan which combines and coordinates the Division's plans. This IE assessment plan will be fon6rded to the Regional Administrators from the Director, IE.

The assessment plans may be revised during the period to redirect efforts and to incorporate views of the IE Director on programs and program areas that should receive emphasis or detailed attention.

It is not anticipated that a detailed review of all program areas or of all aspects of a program area will be required to produce suf ficient information on which to base the assessment of a program.

!ssue Date: 9/1/82

, 0200-051 ASSESSMENT OF REGIONAL IMPLEMENTATION A large portion of the assessment is accomplished through the IE staff audit activities performed in the office. The staff audit activities performed in the office will not necessarily be limited to only the program areas selected for assessment; for example, inspection reports covering various aspects of the inspection program and MIS and 766 data may be reviewed throughout the year.

However, the major portion of the staff audit activities will be concentrated on those program areas selected for assessment.

Records are generated and maintained to document the results of these audit activities The staff audit activities are supplemented by IE assessment trips to licensee facilities to observe inspector practices and to conduct independent verification of inspection findings. The results of Performance Appaisal Team (PAT) and Construction Appraisal Team (CAT) inspections will also be considered in the assessment process. In most cases, the PAT and CAT activities and results will represent the total IE assessment effort with regard to independent verifica-tion at power reactor facilities. Assessment trips by the project ieader and team members will also be conducted at Regional Offices to discuss findings from staff audits and assessment trips, to obtain additional information not available through those assess-ment means, to provide the opportunity at the staff level to inter-act and discuss the assessment findings, and to discuss Regional coments and response.

An assessment report is prepared for each Region upon completion of the assessment of each program area. This Regional Report i summarizes the basis and judgm(nts made regarding the adequacy of program implementation by the Region. The report addresses how the program is being carried out by the Regionel Office in terms of completeness, adequacy, and consistency. Based upon the signi-ficance of the assessment findings and the Region's coments, it may be necessary to schedule a meeting between IE and Regional management to discuss the assessment findings, the Regional comments, and followup activities as a result of problems identified by the assessment process. Normally, this meeting will involve IE and Regional Division management. The Regional Report is prepared by the program Division Director and provided to the Regional Administrator through the Director IE.

Upon completion of the assessment activities for all five Regions in a selected program area, a Summary Report is prepared which

briefly provides an overview of the national implementation (all Regions collectively) of the IE program. The Summary Report addresses the completeness and adequacy of implementation and the i uniformity of implementation both within and among the Regions.

The individual Region Reports will be attached to provide backup and details. The Sumary Report is prepared by the program Division Director and provided to the Regional Administrators from the Director, IE. A copy of the Sumary Report is also provided to the EDO.

l Issue Date: 9/1/82  !- _- _ _ _ _ ____-

• 1 020d-052 -

ASSESSMENT OF REGIONAL IMPLEMENTATION 052 General Conduct and Coordination )

1 The Division or Staff Director will designate individuals as project i leaders with the responsibility to plan and carry out assessment activities for selected programs and program area (s). Staff members will be selected to perform the staff audits and asset.sment trips in each program area and their activities will be coordinated by the designated project leaders.

The project leader will develop plans and schedules for staff audits of regional inspection correspondence, documents and statistical data, assessment trips to accompany inspectors to licensed facilities to observe actual inspection practices or to conduct independent verification if inspection findings, and assessment trips to the Regional Office to discuss observations and to clarify findings. Guidance on the conduct of staff audits and assessment trips to the field and the Regional Office is provided in Appendix 1.

The Directors will identify the project leaders, planned assess-ment activities and assigne staff in the plans (051, above) which are sent to the Office Director and subsequently to.the Regional-Administrators.

053 Schedules and Coordination .

a. Scaff audits will be an ongoing activity during the duration of the assessment period.

b. Assessrent trips will be scheduled and coordinated with the IE Director's Office and the Regional Office. Exact travel dates will be coordinated with the respective Regional Office a minlaus of two weeks in advance o? the planned travel.

c. Assessment trips will be scheduled so th t:

1. Normally no more than one assessment trip will be conducted at the same time in one Regional Office.

2. Normally no more than one assessment trip to a licensee facility will occur at the same time in one Region.

3. Normally no more than two assessment trips to licensee facilities will occur par Region per program area during any 12 month assessment period.

4. Normally no more than one assessment trip to the Regional Office will occur per Region per program area during any 12 month assessment period. '

5. Normally no more than one assessment trip to the field will be scheduled at the same licensee facility during any 12 month assessment period.

Issue Date: 9/1/32 l

, ASSESSMENT OF REGIONAL IMPLEMENTATION 0200-053d

d. The meeting between IE management and Regional Office manage-ment to discuss assessment findings will normally be held within 2-3 weeks after completion of the field activities in the Region if such a meeting is necessary,

e. Regional Reports on IE assessment results for each program area assessed will be prepared during the year as the assess-ment activities for a given Region are completed. Normally these reports will be completed within one month of completion of the field activities in a Region. .

f. Summary Reports for assessment of a selected program area will be prepared upon completion of all Regional Reports on assess-ment of that program area. Normally a summary report will be completed within one month after completion of the last Region Report for that program area. However, all Summary Reports must be completed by no later than June 15.

g. Copies of each Summary Report for assessment of a selected program area will be provided to the EDO. The reports will ,

be provided to the EDO during the year as the assessment  ;

activities are completed, but no later than June 15 of each '

assessment period.

[

END i

I

!ssue Date: 9/1/82 ,

. ASSESSMENT GUIDANCE 0200 APPENDIX 1 ASSESSMENT GUIDANCE Index Part I Review of Program Documentation.................................A-1 Part II Review of Management Information System Data....................A-3 Part III Assessment Trips To Observe Inspection Practices................A-4 Part IV Assessment Trips To Independently Verify Inspection Findings....A-6 Part V Assessment Trips To Regional 0f fices. . . . . . . . . . . . . . . . . . . . . . . . . . . . A-8 Part VI Assessment Report...............................................A-10 Part I REVIEW OF PROGRAM 00CUMENTATION A. PURPOSE Inspection reports and correspondence are reviewed to determine if they conform to expressed policy in general coverage and format, and if violations and problem areas are adequately substantiated as a basis for enforcement action.

The purpose of the review is not to nit-pick the writing style but to determine if the inspection reports and related correspondence are clearly presented and provide sufficient detail to understand and substantiate the inspection activity, findings, and conclusions.

B. EVALUATION GUIDANCE

1. S_nocific 3tandards.

These are requirements 'for format, content and style specified in IE 1005.* While they are specific standards, their application will re-quire judgment by the reviewer. The standards are listed below with references to subsections of IE 1005. Critical elements of certain standards are summarized. Items "a" through "k" cover final inspec-l tion repyts.

1

) a. Cover page (IE 1005-310).

b. Summary (IE 1005-311). T N summary should be a brief narrative description of the scope and results of the inspection. It should specify the dates of inspection and provide a description of the subjects or areas examined, the amount of direct efforts expended in inspector-days (or hours) at the site, and the re-suits of the inspection. Examples are shown in Enclosure 3, s

IE 1005.

• The reference is to IE Manual Chapter 1005. In the revised Table of Contents, this Chapter will be reissued, when revised, as Chapter 0610.

A-1 Issue Date: 9/1/82

t 0200 APPENDIX 1 ASSESSMENT GUIDANCE

c. Persons contacted (IE 1005-321).

d. Action on previous inspection findinas (IE 1005-321). This should be a brief statement of previously noted enforcement and unresolved items examined during the inspection, including de-scription of findings and a notation whether the item remains open or closed. Examples are shown in Enclosures 5 and 6 IE Manual Chapter 1005.

e. Licensee or vendor internc.1 audits (IE 1005-323),

f. Functional or program areas inspected (IE 1005-324).

This is the main body of details of the report which describes the areas inspected and resultant findings. Complete informa-tion must be provided to substantiate violations and other iden-tified ssfety problems.

The report narrative describing violations and safety problems must be complete and purely factual statements of what the licensee did or did not do and the items of proof relied upon to establish each fact. The report should set forth only the relevant facts. It must be objective and present the facts in simple, clear and understandable language with appropriate re-ference to the regulatory requirements and safety standards be-lieved violated. Potential implications of the violations should also be addressed.

Less information is required for those areas inspected and found acceptable, as described in IE 1005-324.

g. Unresolved items (IE 1005-325).

h. Exit interview (IE 1005-326).

i. Report details for vendor inspections (IE 1005-34).

J. Report details for enforcement conferences (IE 1005-34).

4

k. Oraft inspection report (IE 1005-40).

C. DOCUMENTATION In cases where problems are identified, the staff should ensure that the .

project leader and IE management (and Regional management, as appropriate) are informed of the problem in a timely manner. Also problems which may potentially impact the assessment of the enforcement program should be identified to the Enforcement Staff. The documentation of the staff audit activities is important since it will form the basis for the con-clusions and findings presented in the assessment reports. All "negative" findings should be discussed with the Regions and the results of these discussions should be documented.

A-2 !ssue Date: 9/1/82

ASSESSMENT GUIDANCE 0200 APPENDIX 1 Part II REVIEW OF MANAGEMENT INFORMATION SYSTEM DATA A. INTRODUCTION AND PURPOSE There is a significant amount of informetion available from the manage-ment information system (MIS) which will $brm the basis for evaluation of aspects of program implementation. No attempt is made here to enumerate or describe all the data in its various forms. Rather, the guidance gives examples of some of the data that are available.

B. GENERAL Following are examples of data that are available in each program and program area (reactors, vendor materials, and fuel facilities). The information can be obtained for all regions and separately for each region. The data can be obtained for separate licensees, and this may be desirable particularly for detailed evaluation of program imple-mentation for reactors, fuel facilities and the priority I materials licensees.

1. Total number of inspections for a given period, including inspections under a particular inspection procedure.

2. Inspection time expended per procedure.

3. Numbar of inspections that were clear, and the rumber whien identifico violations of requirements.

4. Inspection time expended per clear inspection and for those which identified violations.

5. The number of violations, total and by severity classification.

6. fhe text of citations.

7. The number of citations against a scecific regulation or require- ,

ment.

C. EVALVATION GUIDANCE The evaluation of program implementation includes review of MIS data and i discussions with the regional offices. The evaluation of MIS data is performed by phase of program and by inspection procedure. Information to be considered is discussed in the following sections.

1. Quantitative Evaluation--Phase / Program

a. Completion of inspection phase: ,

(1) periodic inspection procedures are completed within prescribed time intervals.

I (2) one-time procedures are completed within prescribed time intervals.

i Issue Date: 9/1/82 A-3

,0200 APPENDIX 1 ASSESSMENT GUIDANCE

b. Reduced frequency of selected inspection procedures for eligible dockets are:

(1) identified by the regional office.

(2) conducted within prescribed time frames,

c. Resource expenditure by inspection phase:

(1) actual man-hours expended per docket are reasonably con -

sistent with regional and national means, budgetary goals, and planned accomplishments.

(2) variance of actual man-hours from expected man-hours are within reasonable limits.

(3) resource expenditure is reasonably consistent with regional resources, staffing, and manpower planning factors.

2. Quantitative Evaluation Criteria--Individual Inspection Procedure's

a. Resource expenditure:

(1) actual man-hours expended are reasonably consistent with regional and national mean.

(2) variance of actual n n-hours expended from expwcted man-hours are within reasonable limits.

(3) percent completion when procedure is closed is reasonably consistent with program direction; for example, in ab-sence of other instructions, percent completion should normally be 100%.

O. DOCUMENTATION In cases where problems are identified, the staff should ensure that the project leader and IE management (and Regional management, as appropriate) are informed of the problam in a timely manner. Also problems which may potentially impact the assessment of the enforcement program should be identified to the Enforcement Staff. The documentation of the staff audit 1 activities is important since it will form the basis for the conclusions and findings presented in the assessment reports. All "negative" findings should be discussed with the Regions and the results of these discussions should be documented.

l Part III ASSESSMENT TRIPS TO OBSERVE INSPECTION PRACTICES A. PURPOSE ,

IE staff accompany inspectors to determine if inspection procedures are interpreted and implemented in a complete, adequate and consistent manner.

A-4 Issue Date: 9/1/82

ASSESSMENT GUIDANCE 0200 APPENDIX 1

. The purpose of accompanying inspechrs during the course of their work is not to inspect the inspector and identify "noncompliance" by the inspector with the inspection procedures. The IE staff should also identify to the licensee the purpose of the assessment trip.

In carrying out this part of the assessment process, the emphasis is on determining completion of the intent of the program (other expressions of

• the same idea are: (1) completion of the substance of the program, (2) substantially complete, and (3) in all important aspects, complete).

Significant variations either in excess of the intent or less than the t intent are to be examined closely to find out the reason so problems may '

be corrected.

Limitation: The IE observer is not inspecting the licensee. The reviewer's job is to independently observe the inspection activity and to examine in parallel with the Regional inspector the areas inspected.  ;

8. EVALUATION GUIDANCE The guidance is general and given in terms to aid the reviewer in plan-ning and carrying out the review activity. The reviewer must have a thorough knowledge of the program requirements and inspection procedures under which the inspection is being performed, and a general idea of how the inspector intends to carry out the inspection. '

1. Using the inspection procedure (s) and the inspector's plan, under- I stand what the inspector intends to inspect and how he plans to do i i t. Do not question the adequacy of these plans, advise the inspec-  !

tor how to inspect, or question his methodslogy or techniques in '

front of the licensee. ,

• l

2. Observe the inspector during the entfre time he is inspecting each l part covered by his plan. Take notes so that you can remember what the inspector di3 and you can later document how major parts of the  ;

inspection were carried out. Note the time spent on each function l or separable part of the inspection and make notations to explain '

times which seem to be long (for example, considerable effort required to confirm, clear, or resolve problem issues).

3. Understand what the inspector is looking for in a record review, {

what specificaly he is lookir.g for in observational activities, l and what he is probing for in discussions with licensee personnel, i This understanding is arrived at before or af ter the fact, of course, and in a manner not to interrupt the inspector (ion). [

4. For each segment of the inspection evaluate whether the activity i being done by the inspector is consistent with the requirements and guidance of the inspection procedure. Remember the emphasis is l

! placed on determining enepletion of the intent of the program, and i not each specific detail of the procedure. If the inspector is i looking at matters you believe not within the intent of the overall ,

j program, find out why.  !

l Issue Date: 9/1/82 A-5

0200 APPENDIX 1 ASSESSMENT GUIDANCE C. DOCUMENTATION For each inspection procedure or logical inspection procedure grouping the IE staff member should maintain field notes which consider / address each of the following topics:

1. What was inspected.

2. How the inspection was accomplished: methodology, what was observed, how many observations were made, who was talked to, what records were checked, and for what purpose.

3. Whether the inspection verified or evaluated what the program intended? If not, explain.

4. Whether the inspection covered more than was intended by the pro-gram? If so, explain.

5. Whether the inspection covered less than was intended by the program? If so, explain. (If this was the inspector's plan, or if all parts could not be done for some reason, say so.)

6. Amount of time taken to accomplish the inspection, or logical segments thereof? If more or less time was taken than the evaluator believes necessary, state how much time should be spent and the reason for the difference.

7. The staff should provide to the enforcement staff any conclusion regarding enforcement action.

Part IV ASSESSMENT TRIPS TO INDEPENDENTLY VERIFY INSPECTION FINDINGS A. PURPOSE The purpose of IE staff members traveling to licensee sites and indepen-dently conducting selected inspection activities is to provide feedback on the conpleteness, adequacy and consistency of regionally reported inspection findings. It is anticipated that such assessment trips by IE will comprise a small percentage of the total assessment effort. In seme l program areas, these assessment trips may not be warranted. When such assessment trips are planned, specific inspection areas or procedures will be selected for independent verification. In most cases, the PAT and CAT activities and results may represent the total or major IE assessment effort with regard to independent verification of Regional inspection findings at power reactor facilities.

! Detailed planning is required to ensure that a comparison of regional l inspection findings and IE assessment findings can be made. In this situation much of the assessment effort will be focused on independently inspecting operational characteristics or documentation which remain relatively constant with time.

A-6 Issue Date: 9/1/82

ASSESSMENT GUIDANCE

. - 0200_ APP _ENDIX 1 B. EVALUATION GUIDANCE The guidance is general and given in terms to aid the IE Staff member in planning and carrying out the inspection activity. The reviewer should have a thorough knowledge of the program requirements and inspection procedures under which the inspection is to be performed and a specific plan of how the he intends to carry out the inspection.

The reviewer should review and have thorough knowledge of the facility and operations at which he will conduct the inspection.

1. Make arrangements with the Regional Office to inform the licensee at least 2 weeks in advance of the planned travel and identify to the licensee the purpose of the trip. Coordinate the scheduled travel with the Office of the Director, IE before finalizing travel arrange-ments.

2. Using the inspection procedure (s) and the inspection plan, under-stand what you intend to inspect and how you plan to do it. During the inspection take notes so that you can remember what you did.

Later you can document how major parts of the inspection were carried out. Note the time spent on each function or separable part of the inspection and make notations to explain times which seem to be long (for example considerable effort required to confirm, clear, or resolve issues).

3. Understand what you are looking for in a records review and what specifically you are looking for in observational activities.

4. Document all findings relevant to the inspection that should be forwarded to the Regional Office for followup. Inspection findings should be identified to the licensee upon completion of the inspec-tion. Explain to the licensee that these findings will be forwarded to the Regional Office for followup. Also document the finding re-levant to the assessment activities and findings as indicated .n i Section C below.

5. Comt,are your inspection activities and findings with the Region's.

Examine for each activity and compare:

a. Scope of coverage

b. Oepth of inspection

c. Consistency of inspection activities

d. Findings and related significance

e. Time expended C. DOCUMENTATION For each assessment trip to independently verify regional inspection findings, the IE staff member should maintain field notes which address:

l Issue Date: 9/1/82 A-7 i . ___ _ _ _ _ _ _ . - _ - - - - - - - . - - -

0200 APPENDIX 1 ASSESSMENT GUIDANCE

1. IE Field Inspection

a. What was inspected?

b. How the inspection was accomplished: methodology, what was observed, how many observations were made, who was talked to, what records were checked, and for what purpose?

c. Whether the inspection verified or evaluated what the program intended? If not, explain-

d. Whether the inspection covered more than was intended by the program? If so, explain.

e. Whether the inspection covered less than was intended by the program? If so, explain.

f. Amount of time taken to accceplish the inspection, or logic 2l segments thereof? If more or less time was taken than the reviewer believes necessary, state how much time should be spent and the reason for the difference. .

2. Comparisor af IE Field Inspection to Regional Inspection Results

a. Scope df coverage

b. Depth of inspection

c. Corsistency of inspection activities

d. Findings and related significance

e. Time expanded

f. Conclusions on acceptability of comparision and regional implementation and documentation of the program.

3. The IE staff member should provide to the Enforcement Staff any conclusions regaroing enforcement actions.

Part V ASSESSMENT TRIPS TO REGIONAL OFFICES A. PURPOSE IE assessment trips to regional offices should be the culminating activity in the staff review process; that it, after a review of MIS data, review of a sample of program documents, and assessment trips to the field. Gen-erally, the purpose of the assessment trip to the Regional Office will be to discuss the interim results of staff audit activities with regional supervisors and inspectors, obtain additional and clarifying information, and to provide and obtain information of mutual interest regarding pro-grammatic problems and improvements. The trips are planned with defini-tive objectives. The trips are not made for the purpose of searching for targets of opportunity in the program assessment process.

A-8 Issue Date: 9/1/82

ASSESSMENT GUIDANCE 0200 APPENDIX 1 B. PLANNING AND CONDUCT

1. The results of the staff audit activities should be assembled and organized to aid the development of the plan and agenda for the trip.

The plan and agenda may be organized on the program and program areas to be discussed.

2. The agenda shuuld be complete and descriptive enough to clearly identify the main thrust and purpose of the topics to be covered.

For example, if part of the trip is to obtain information or view-points, the importa:it relevant questions should be spelled out in the agenda. Likewise, if results of audit activities are to be discussed, the results should be (or have been) provided to the regional office and the topic (s) described in the agenda.

3. One part of the meeting in the regional office should be devoted to an open discussion with the inspectors (group or individuals) for obtaining, first-hand, their views and comments on the IE assessment program and program findings.

4. Time and dates of the trips to the Regional Office will be arranged with the regional staff that will be involved. The agenda will be sent by mem<.,randum to the Regional Administrator through the Director, IE. This written notice should be in the hands of the region at least two weeks in advance of the scheduled visit.

5. All assessment trips are to be coordinated with the Office of the Director, IE.

C. DOCUMENTATION Ouring each assessment trip to a Regional Office, the IE staff member should maintain field notes which address:

1. Specific problems / concerns discussed incl'uding source or basis for the concern e.g., MIS data, inspection reports, observations from inspector accompaniments, etc.

2. Personnel contacted for each item.

3. Resolutions / conclusions pertaining to each item on the agenda.

4. Listing of Regional coments regarding weaknessas or proposed changes in the assessment program.

5. Any Regional response, comments, or proposed action partaining to the assessment findings.

6. Any conclusions regarding enforcement action should be identified to the Enforcement Staff.

Issue Date: 9/1/82 A-9

0200 APPENDIX 1 ASSESSMENT GUIDANCE Part VI ASSESSMENT REPORTS A. PURPOSE The purpose of the assassment report is to document the IE evaluation and findings of the mannner in which the inspection and enforcement program is implemented for each program or program area selected for assessment. There are two types of assessment reports:

(1) A Regional Report which is prepared for each Region upon completion of ass.essment activities for a selected program or program area for that Region, and (2) A Sumary Report which provides an overview of the assessment results for a selected program or program area for all five Regions. The Regional Reports will be attached to the Summary Report to provide backup and details.

B. REPORT PREPARATI0id

1. General -

The assessment report provides the ritten record of the IE assess-ment of the Regional implementation of the program or program area selected for review. The report should be concise. A brief sumary af the assessment activities should be provided which identifies the dates and location of all site visits and visits to the Regional Office and outlines the basic plan for assessment.

The report should sumarize the basis and judgments made regarding the adequacy of progrsm implementation by the Region. The report shoula adoress now the program is ceing carried out by the Regional Of fice in terms of completeness, adequacy, and consistency. If a meeting between IE and Regional management was held, the meeting discussion topics and results of the meeting should be included in the report. Any Regional response, coment, or corrective action taken in response to the assessment findings snould also be included in the report.

The statements in the report should be clear and factual. Assess-ment conclusions should be supported by assessment findings. The report should present a fair and unbiased summary of the assessment activities and results.

Sach Regiona'. Report should generally bq dispatched within one month after completion of the last field assessment trip to each Region. The Sumary Report should generally be dispatched within one month after completion of the last Regional assessment report.

All reports will be completed no later than June 15 each year.

Regional Reports will be addressed to the Regional Administrator from the appropriate Division Director thru the Office Director while sumary Reports will be prep'ared by the Division Director for the signature of the Office Director to the Regional Admini-strator.

A-10 Issue Date: 9/1/82

ASSESSMENT GUIDANCE 0200 APPENDIX 1

2. Format The assessment report should have the following general layout:

Scope - This section identifies the program or program area selected for assessment.

Assessment Activities - This section identifies the in-office activities and the dates and location of travel to the Regional Office and licensee sites. In the Summary Report, this information can be summarized to indicate (X) trips to licensee sites and (Y) trips to the Regional Office during the assessment period.

Assessment Findings - This section addresses the results obtained during the assessment regarding the Regional Office's implementation of the IE program.

The assessment results should address the completeness, adequacy and consistency of implementation. Only significant findings should be identified. No nits! Results of IE and Regionai management meetings should also be addressed in this section. Copies of each Regional Report will be attached to the Summary Report to provide the necessary details and backup information.

Assessment Conclusions - This section provides a brief summary statement of the IE assessment of the Regional Office's implementation of the IE program. The conclusions should be ,

clearly stated, factual, and supported by assessment findings.

3. Assessment Factors The assessment factors described below are to be considered in assessing the Regional implementation of the IE program. The factors have been grouped under three headings: program completion, performance adequacy, and implementation consistency. For each factor, attributes are also provided as guidance to facilitate the overall assessment process.

In assessing a program area it may not be necessary (or possible) to consider all the assessment factors. At least some of the factors regarding program completion, perfomance adequacy and implementation consistency must be considered for program areas selected for assessment.

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!ssue Date: 9/1/82 A-11 '

1

V 0200' APPENDIX 1 ASSESSMENT GUIDANCE

a. Program Completion Factors. These factors should be considered in determining if program goals and planned accomplishments have been achieved.

1. Frequency. Inspection Procedures (IP) conducted in accordance with the prescribed frequency.

2. When recuired. Inspection procedures conducted when requirec by events.

3. Insoection Procedure Completion. Individual IPs are closed at 100 percent complete or there is a basis for closing IPs at less than 1005.

4. Timely Issue of Documentation. Inspection reports, memoranda, ate. are issued within a reasonable time frame.

b. Performance AdeQuny Factors. These factors should be considered in determining if program policies, procedures, and priorities are interpreted as intended. _

1. Scope. The scope of the inspection activity is consistent with that prescribed by the IP. *

2. Oeoth. The technical depth of the inspection activity is

consistent with that prescribed by the IP or as warranted 4

i by the findings.

4

3. Focus on Safety Issues. When the inspection activity identifies issues of safety significance, the safety issues receive followup in accordanca with established

procedures.

! 4. _ Identification of Trends. Issues are evaluated for significance--are the issues important to safety, l indicative of a trend or generic issue. Where appro-i priate, the inspection activity focuses attention on

! identified trends or generic issues.

j 5. Resource Utilization. Resources are efficiently employed.

Inspection activities are conducted by individuals properly trained and qualified for the inspection activity l,

conducted.

6. Lnforcement Threshold. Enforcement action is initiated l

l where appropriate and is consistent with published

policies and procedures.

! 7. Enforcement Bases. Enforcement actions are soundly i supported by the facts of the case.

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A-12 !ssue Date: 9/1/82

(

ASSESSMENT GUIDANCE 0200 APPENDIX 1

. 8. Documentation and Correspondence. Documentation is consistent with program requirements and provides a clear record of accomplishment of inspection procedures.

Findings are clear and concise. Related correspondence is clear.

9. Licensee Contacts. Meetings and contacts with the licensee are in accordance with established policies.

This includes entrance and exit interviews, other licensee meetings, and day-to-day contacts between the i inspector and licensee personnel. ~

c. Implementation Consistency Factors. These factors should be considered in determining if the IE program is implemented consistently among the Regional Offices or among similar licensees. (Certain events that may severely impact a parti-cular region may obviate portions of this part of the assess-ment process. Planned adjustments to the program, based on SALP do not constitute inconsistencies).

1. Program Completion. The degree of program completion by the regions should be similar. Program completion at different facilities (that are in the same phase) should be consistent unless there are documented circumstances to account for major dif ferences.

2. Scope. The scope of inspection activity is similar among regions and among facilities.

3. 02pth. The technical depth of inspection activity is similar among regions and among facilities.

4. Focus on Safety Issues. The regions provide similar scope and depth attention and followup to safety issues.

, 5. Resource Utilization. Resources are employed in a

similar manner among regions and are consistent with '

requirements prescribed by the program. The manpower expenditure to complete a given portion of the program  ;

is consistent among regions (other parameters being equal).

! d. Implementation Attributes The attributes presented in Table 1 can be used to characterize the degree of successful implementation of a selected program or program 4 area for each assessment factor. Use of these attributes by the assessment staff is encouraged to provide for more consistent and uniform assessment of the Regional implementation of the IE Program.

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! Issue Date: 9/1/82 A-13 i

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Table 1 Implementation Attributes For Each Assessment Factor -

Full Implementation Acceptable Implementation Limited Implementation i

j Program Completion Factors frequency Inspection procedures conoucted Inspection procedures humerous instances of IPs not within prescribed frequency in usually conducted within completed within prescribed fre-almost all cases. frequency. quency.

Deviations from prescribed fre- Deviations from prescribed Numerous instances of devia-quency dictated by SALP are met frequency are usually in tions free prescribed frequency; in almost all cases (reactors accordance with SALP re- SALP requirements seldom met only). quirements (reactors only). reactors only).

When Required IPs are conducted in nearly all IPs are usually conducted Numerous instances of IPs not cases when required by events or when required by events or conducted in response to licensee activities. licensee activities. licensee events or activities.

IP Completion Nearly all IPs are fully IPs are usually fully com- Numerous instances of IPs that pleted (closed at 100%). completed. are incomplete and "window of opportunity" has passed.

limely Issue of Timely issuance in nearly all Documents are usually issued Documents are often late; ex-Documents cases. In a timely manner. tensions to deadlines are fre-quently sought.

Pcrformance Adequacy Factors '

scope Scope of inspection effort is Inspection effort usually Inspection effort not thorough consistent with effort prescribed. seets prescribed scope. and omits portions of pres-scribed effort.

Depth The technical depth of the inspec- Technical depth of inspec- Inspection effort reveals in-tion effort is consistent with tion effort is usually stances of inadequate tech-the requirements of the IP in consistant with IP require- nical depth or merely a cursory nearly all cases. ments. review of significant issues.

Implementction Attributes Fer Each Assessment factcr Full Isplementation Acceptable Implementation Limited Implementation -

Depth (continued) the experience and training of Inspector experience and Weaknesses in inspector exper the in.pectors is commensurate training is usually com- tence and trainin(' found to with the assigned iaspection mensurate with the assigned be a major contriLating

.ctivity. inspection activity. factor to poor understanding of inspection requirements or criteria.

focus on Safety inspection effort focuses on sig- Inspection effort usually Numerous instances of nificaat safety issues; identified focuses on significant safety issues that were issues receive prompt followup safety issues; prompt fol- overlooked; followup of in nearly all cases. lowup is usually made. identified issues is not timely.

Lignificant safety issues that Newly identified safety Newly identified safety are identified but not addressed issues are usually for- issues are frequently not in the prescribed program are warded to IE for incorpora- forwarded to IE for incor-torwarded to IE for incorporation. tion in prescribed program. poration in the prescribed program.

Identification of Irends or generic issues are iden- Trends or generic issues Numerous instances where Irends t ified as appropriate in nearly are usually identified. trends or generic issues all cases. were overlooked.

Significant trends or generic Significant trends or kumerous instances where issues are identified to lice nsee generic issues are usually trends or generic issues dnu appropriate NRC organization identified to licensee or are not identified to in nearly all cases. appropriate NRC organiza- licensee or appropriate tien. NRC organization.

R: source Utilization Resources are ef ficiently employed Resources are usually effi- Numerous instances of in nearly al! cases ciently employed. resource inefficiency.

Consistent evidence of prior plan- Usually evidence of prior Little evidence of prior ning and assignment of priorities. planning and assignment planning or assignment of priorities.

1 j

. - - - - - . _ - ~ . - - . _ - - - _ - _ - _ . . _ - - - . - - - _ - _ . . _ - . _ _ - - . - - . . .

j Implementation Attributes for Each Assessment Factor j Full Implementation Acceptatie implementation ' u lted Implementation . -

1 1

! Enfcrcement Enforcement strong, prompt, and Enforcement usually aggres- Numerous instances where

! Ihreshhold consistent with policy; level of sive, prompt and consistent eaforcement actions are weak, i

sanctions applied (proposed) are with policy; m1 of sanc- tardy, or incou lstent with appropriate to circumstances in tions applied (proposed) is policy; level of sanctions

nearly all cases usually aspropriate. applied (proposed) may be

inappropriate.

t i Enforcement Bases taforcement actions are soundly Enforcement actions are Numerous examples where i supported by the facts in nearly assually well supported; bases for enforcement i all cases; little additional j

some additional research actions are unclear; fre-research is required to complete may be required to com- quent cases unere clarifi-i l

I staff work in support of enforce- plete staff work in sup- cation is saught by the ment actions. port of enforcement actio,i. Ilcensee prior to his

response to an enforcement

action.

i Documentation and In nearly all cases, inspection Inspection reports usually Numerous instances of Ccrrespondence activity and relationship between provide a clear record of unclear inspection reports;  ;

report and inspection procedure inspection activity and fragmentary narratives.

, is clear; findings are clearly establish relationship l

i stated. between report and inspec-tion report; findings are l! usually clearly stated; i

Memoranda, forms, etc. related to Memoranda, forms, etc. re- Numerous instances of incom-inspection etfort are completed lated to the inspection plete or poorly completed menos, i j

properly in nearly all cases. efforts are usually com- forms, etc. related to inspec-plated. ' tion.

,4 jticenseeContacts Licensee contacts and meetings are Licensee contacts are Numerous instances of unclear, '

i j clear, concise, and well directed usual)y timely, clear and tardy or confusing contacts '

in nearly all cases, contact with are11-directed. with the licensee.

licensees is is timely.

1

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l. . . . _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . . ._ _ . _ _ . . . _ _ _ _

Implementction Attributes for Each Assessment factor Full Implementation Acceptable Implementation Limited Implementation . -

Licensee Contacts Initiative is displayed when Licensee usually contacted Many contacts with licensee (continued) contacting Ilcensee in r'esponse in response to events. are initiated by licensee.

Lo eveats.

Implementation Consistency Factors Program Completion Degree of program completion is Degree of program comple- I merous examples of incon-consistent in nearly all cases tion is usually consistent sistent program completion.

(when compared among regions or I among facilities).

i Scope Scope of in'.pection effort is con- Scope of inspection effort Numerous axamples of incon-sistent in nearly all cases (when is usually consistent. sistent scope of inspection I compared among regions or among effort. i I

facilities).

, Depth 1he depth of inspection effort is The depth of inspection Numercus examples of incon-consistent in nearly all cases effort is usually con- sistent depth in inspection l

(when compared among regions and sistent. effort.

among facilities).

focus on Safety The focus on safety issues is con- The focus on safety issues Numerous examples or incon-sistent in nearly all cases (when is usually consistent. sistent focus on safety compared among regions and among issues.

facilities).

R2 source The use of resources is consistent The use of resources is Numerous examples of incon-l Utilization in nearly all cases (when compared usually consistent. sistent use of resources.

among regions and among facilities).

l I Enfercement In nearly all case:3, the applica- The application of enforce- Numerous examples of inconsis-j Application tion of enforcement sanctions is mes t sanctions is usually sistent application of enforce-l consistent for all events (when consistent. ment sanctions.

compared among regions and among -

l facilities).

-____- .-_ _ _ _ - - __. . _ _ . _ = _ ._ . .

Implementation Attributes for Each Assessment Factor Full Implementation Acceptable Implementation Limited Implementation ,

Documer tation In nearly all cases similar Siellar items are usually Numerous examples of incon-items are documented in a documented in a similiar sistect documentation.

similar manner (when compared manner.

among regions and among faci-lities).

Liccesee Contacts .In most. cases, contacts and Contacts and meetings with Humerous examples of incon-meetings with licensees are licensee are usually con- sistent. contccts and consistent (when compared sistent. meetings with licensees.

among regions and among faci-lities).

t is 5-

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IE PLAN FOR ASS!SSMENT OF REGIONAL IMPLEMENTAT4 0N OF IE PROGRAMS A. REACTORS 1.

a. Program Area - power reactor safeguards (selected inspection procedures from 8100 series)

b. Applicability - all five Regions

c. Assessment Team - W. Fisher, roject leader; N. Ervin and one '

additional staff member

d. Assessment Schedule - November 82 to April 83 Staff audit in office - November 82 Assessment trips to five licensee sites and each Regional Office - December 82 to March 83

-- Report Preparation

• Regional Report - cre month after travel Suerary Report - April 83 '

2.

a. Program Area - power reactor radiation protection and environmental monitoring (inspection procedures 83741,83742,and83530)

b. Applicability - all five Regions

c. Assessment Team - W. .tisher, project leader; J. Buchanan; L. Cohen; and one additional staff member

d. Assessment schedule - September 82 to February 83

-- Staff audit in office - September 82 Assessment trips to five licensee sites and each Regional Office -

October 82 to January 83

-- Report preparation Regional Report - one month after travel Summary Report - February 83 i i  !

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3.

a. Program Area - regional implementation of SA!.P (NRC Manual Chapter 0516) i

b. Applicability - all five regions

c. Assessment team - P. McKee, project leader; two additional staff members

d. Assessment schedule - October 82 to March 83

-- Staff audit in office - October to November 82

., -- Assessment trips

-- Attend SALP Board Meetings - December 82 to February 83 .

-- Attend Regional meetings with licensee - Deceder 82 to February 82

-- Report preparation

-- Regional Report - one month after travel

-- Swinary Report - March 83 B. EMERGENCY PREPAREDNESS 1.

a. Program area - Regional responte capability l

h. Applicability - all five Regions I

c. Assessment team - Eric Weinstein, project leader; team members to be i detemined

d. Assessment schedule - August 82 to June 83

-- Staff audit in office and preparation . August to September 82 I

-- Assessment trips to Regional Offices

. Region I October 19-21,1982 l

. Region !! November 30-December 2, 1982

=

F

,'/ .

. Region !!! April 5-7,1983

. Region IV March 15-17,1983

. Region V January 25-27, 1983

-- Report Preparations

-- Regional Report - one month after travel

-- Sunmary Report - June 83 C. FUEL FACILITIES AND MATERIALS 1.

a. Program Area - physical protection of SSNM ir ..ansit (inspection procedures 81.350-81390)

b. Applicability - Regions I, !!, and V

c. Assessment team - W. Brown, project leader; J. James; R. Blackmon; L. Bush, team members

d. Assessment schedule - A'1ust 82 to January 83

-- Staff audit in office - August 82

- Assessment trips - to be scheduled during August - October, ,

\

dependent upon schedules for shipments

-- Report preparation  !

-- Regicnal Report - one month af ter travel

-- Sumary Report - January 83 2.

a. Program Area - physic.a1 protection of Group 1 fuel facilities (inspection procedures 81218-81290)

b. Applicability - Regions !  !! and V i

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c. Assessment team - W. Brown, project leader; J. James; L. Bush; R. Blackmon, te e, members

d. Assessment schedule - August 82 to January 83

-- Staff audit in office - August 82  !

-- Assessment trips

. Region ! UNC-M October 82

. Region !! NFS August 2-6, 1982 B&W NNFD August 2-6,1982 '

. Region V GA , August 9-13, 1982

, Regional Offices November 82

-- Report Preparations l

-- Regional Report - one month after travel  !

-- Swinary Report - January 83 l

3.

a. Program Area - radiological safety program for fuel facilities (Manual a

1 Chapter 2600, 2640, 2650, and 2660)

b. Applicability -- all five Regions (

\

c. Assessment Tean - R. Paulus, project leader; D. Sly; J. Metzger; L team members

d. Assessment schedule - July 82 to January 83

-- Staff audit in office - July to August 82

-- Assessment trips

. One Licensee site in RIY -

September 82

. . One Licensee site in RI September 82 l

l .

One Licensee site in RII & V October 82 '

f 1

~5-

. One Licensee site in RI!! November 82

. Regional Offices, RI, !! &

!Y November 82

. Regional Offices. RI!! & Y December 82

-- Report Preparation

-- Regional Reports - ona month after travel

-- Swmary Report - January 83

4. (

a. Pmgram Area - radiological safety program for materials (Manual Chapter 2800,2005,2830,2850,and2860)

b. Applic$111ty - all five Regions

c. Assessmeht team - R. Paulus, project leader; D. Sly; J. Metzger; team members ,

d. Assessmer.t schedule - July 82 to January 83 '

-- Staff adit in office - July to August 82

-- Assessment trips

. One Licensee site in RI & !! September 82

\

. One Licensee site in RIV September 82

. One Licensee site in RI!!, IV, t

&V October 82  ;

. One Licensee site in RV November 82

. Regional offices, R!, !! & IV November 82

. Regional offices R!!! & V December 82 [

(Region'al Office travel will be in conjunction with item C.3 !

above, assessment of the radiological safety program for fuel facilities)

-6

-- Report preparation

-- Regional Report - one month after travel

-- Sumary Report - January 83

0. VENDOR PROGRAM 1.

t

a. Program area - vendor reactive program (Manual Chapter 2720)

b. Applicability - Region IV

c. Assessment team - M. W. Peranich, project leader; G. Georgiev; D. Osborne; T. Le; D. Norkin; team members ,

d. Assessment schedule - December 82 to May 83

-- Staff audit in office - December 82 to January P3

-- Assessment trips

. Two or three vendor sites February to March 83

. Region IV April 83

-- Report Preparation

-- Swinary report - May 83  :

E. ENFORCEMENT PROGRAM 1.

a. Program area - general overview of the enforceaant program in each Region

b. Applicability - all five Regions

c. Assessment team - to be determined

<i . Assessment schedule - Nov' ember 82. to March 83 Staff audit in office - November 82 to March 83

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4 MC % IE HEA0 QUARTER'S EVALUATION OF THE NRC ENFORCEMENT PROGRAM o

PURPOSE _

The purpose of this Manual Chapter is to describe the program by which IE headquarters (X00S) wiLL evaluate regional and headquarters divisional implementa-tion of the NRC enforcement program.

APPLICA8ILITY i

This chapter applies to the Executive Officer for Operations Support's evaluation of the implementation of the NRC enforcement program. Specifically for those er, srcement activities assigned to the Executive Officer for Operations Support for the purpose of evaluation.

Objectives

1. To improve the NRC enforcement program.

2. To standardize the application of enforcement policy in all IE regions and divisions.

3. To provide a basis for management's atlocation of NRC resources.

4. To assist regional and headquarters management in identifying problem areas in the implementation of the NRC enforcement program.

Discussion _

This MC provides a formal and consistent methodology for evaluation of the implementation of NRC's enforcement progran. It is the intent of this Chapter to cover alL programmatic areas and all levels of enforcement including the --

day-to-day enforcement activities of site, regional and headquarters personnel.

The purpose of this' evaluation program is not to change or establish new NRC

% sea.lvaNam enforcement policy. ...... , i; is to determine the degree of conformance of

staff actions to existing policy and to make recommendations to headquarters management on NRC enforcement program improvement.

Evaluation Techniques and Pertennel Reauirements Staff work for the enforcement e.'a,Luation program wiLL be completed by one or mot e Enforcement Specialists fromhadquarw. 2. The e. valuation wiLL cover all disciplines within a given re io at office or division, where possible but j f in no case wiLL less than hal tie disciplines represented be reviewed. ALL evaluations shall be scheduled in advancej and any office to be evaluated shall /~

be notified of this schedule prior to the evaluation.

The evaluation wiLL consist of document review, personnel interviews, and, where possible, direct observation of cases in progress at the time of the evaluation. The evaluation will --"' - - ':.... .. . '-a= + ' - - ' - * " -

view M r.. :: ' " ---- ' "a enforcement action, by seversh Ames/

qndsogrouptheenforcement activities examined. The process followed wiLL be: (1) review of those documents available at headquarters; (2) review of necessary documents at the division or region of concern; (3) interview of personnel involved in the enforcement process; and (4) observation of the enforcement process.

Reporting The Enforcement Specialist (s) conducting the evaluation wiLL submit a draft i

report to the Director of the division or office whose participation in the l

enforcement program was evaluated. The Director's comments wiLL be considered f in preparing the final report to the & M b:w WLT i-- ^ ' ' i ; ; . ': .- 0.. . . ic:: E;; r t .

The Director's comments will be attached to the final report.

s on a semi-annual basis, a sumary report wiLL be made to the Executive Officer for Operations Support by the Senior Enforcement Specialist. On an annual 4 basis, a comprehensive report to the Director, IE on the overall application

. i of the NRC enforcement program wiLL be made by the Executive Officer for Operations Support.

• r Evaluation Cvela Each ...... : 1_ ion wiLL be evaluated once within each 24 month period. '

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ENCLOSURE I I. GENERA _L The evaluation program wiLL cover the following enforcement areas:

a. Severity levels

b. Notices of violation

c. Civil penalties .

d. Orders e

(Enforcementconferences)

- f[Noticesofdeviation}s

g. Immediate action Letters -

h. Referral to Department of Justice

, -_-_..n._ 2.__

The program wiLL be divided into four phases: (1) review; (2) interview; (3) observation; and (4) comparison. Reports wilL include individual and periodic summaries of enforcement program implementation and recssmendations for change.

The review portion of the program will be conducted at headquarters when possible. The review wiLL be documented on "Review Forms,". These forms are attachments to this document. At the end of the e,v pha e

, 4 preliminary report wiLL be written and submitted to Me trust of this report wiLL be to identify possible problem areas and outline the emphasis to be placed on phase II interviews.

The interview portion of the program wilL be conducted at the appropriate region or at headquarters for the divisions. The office to be interviewed will be notified in advance of the interview date and the subject matter.

. s i

2-Observation wiLL consist of attending enforcement conferences, exit interviews, regional and division enforcement meetings.

Comparisons wiLL be made between regions and divisions to illustrate standard and nonstandard enforcement policy applications. These comparisons wiLL be the principle subbict for reports issued at the end of, the review period.

II. EVALUATION PROGRAM A. REVIEW

1. To property review a region or division, identify and List each major type of Licensee, example; power reactor, material, test reactor, vendor, etc. Under each heading list the names of Licensees in that region. Review the file of each Licensee until enough inspection reports, generated since the last review period, have been reviewed to identif addocumentfjve xa es of eaci

.---r- , b- r-

• *'*d9 d severity leve)L (for each type of Licensee). When the documentation

• • ' d 4

is completed proceed to the checks below

a. Each severity level.

(1) Insure that each example conforms to Commission enforcement policy statementsjand that each example meets the requirements of MC 0800. This wiLL require a review of current commission papers on enforcement and a review of commission accepted examples of each severity Level. Examples can be found in appropriate appendices to commission papers and MC 0800.

b. Notice of violations.

(1) For those severity Levels that warrent notices of violation insure that such notices were sentjand that the notices -

conformed with policy as stated in NRC MC 0800. MC 0800

_3_

references 10 CFR 2.201. This 10 CFR sets the requirements of the. notice and the requirements of the Licensee's reply. After assuring that the notices meet the criteria of the MC and 10 CFR 2.201, examine the replys for items (a) (.1), (2), and (3) of 10 CFR 2.201. Document aLL findings on notice of violation review form.

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• nhane, (2) Complete the civil penalty review form. A principle objective of this form is to ea<stablish examples of each category of civil penalty. These examples can be used as an aid in the standard application of vi<<

civil penalty.< policy.

1 (3) Document and compare, against established policy, the circumstances verses the dollar amount of the penalty.

For example, be alert to situatuions wh<<<

l For example, be alert to situations where: mitigation was  ;

warrented and not given; the civil penalty was mitigated, .

and the reasons for mitigation are not within the established criteria; the assessed penalty was not I l

in the si<ame dollar range when compared with other penalties of the same type; ti.4 civil penalty was inc<- l creased due to repetive itens of non-compliance; and, j

~. t repetive items existed but no increase in the civil l

l penalty resulted. l 1

L (a) It is important to establix<sh precedences where repetive items of non-compliance are involved. Document each case, and address each caseintheinterviewp[ase.Seekthereason

& M for making the d/ cision, and develope a suma/ry.

A Add that summary to the appropriate section of the Civil Penalty Book. Include this summary intheperiodicrepr}tsmad3<etoalloffices.

7

d. Orders hhM/r%

m e,Saosass** @ Y N _ W _[*' A .

(1) Review :: '. n t ' ' - - "

d 6 e of each type, i.e., cease and desist, suspend a license, modify a license, revoke a license, rescind a previous order, etc. Use your judgement in conoling theseordersforrevieg[o4a+esomeofthetypesmaynothave been issued in the earied since the last review. Complete the .

9 review form

( 2)' Document the activity preceding the ordert was an opportunity C.

to take 3orrective action given in advance of the order; did a notice of violation precede the order; was there a finding that the health and safty of the public required issuance prior to advance notice; and, was there a finding of deliberate noncompliance.

(3) Document thatjence the order was issued, the issuing office determined compliance with the order in accordance with the requirement l contained therein.

l l (4) Insure that all orders reviewed have established and management I

accepted 3 esamples. Identify any orders that do not have such an example,and develope an example of ?;;: :-d:-s for management l

1 review. Af ter review and con urrance)these e.g examples would be added to MC 0800 espeammmes pendtt- .

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ITEM yes b.

i. AFROPRIATE APPENDIX & NUMBER

2. Level II

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