ML20151L000
| ML20151L000 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20151L006 | List: |
| References | |
| FOIA-88-42 NUDOCS 8507030703 | |
| Download: ML20151L000 (3) | |
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%,,.....f June 26,1985 MEMORANDUM FOR: Dennis F. Kirsch, Acting Director Division of Reactor Safety and Projects, Region V Ross A. Scarano, Director Division of Radiation Safety and Safeguards, Region V FROM:
James G. Partlow, Director D' ision of Inspecticn Programs
( ' ice of Inspection and Enforcement
SUBJECT:
ASSESSMENT OF IMPLEMENTATION OF REGIONAL INSPECTION PROGRAMS ADMINISTERED BY THE DIVISION OF INSPECTION PROGRAMS,(DI/IE)
The enclosure 20 this memorandum contains a program assessment of regional inspection aethities over the past year in those areas administered by this Division.
The assessment attempts to bring together both the quantitative and subjective information available to the DI staff.
The assessment is based upon such activities as:
- The conduct of PAT, CAT and other independent inspections by IE.
- Accompaniment on regional inspections.
- Assessment visits to Regional offices.
- DI review of inspection reports and data systems.
- Observation of SALP activities.
- Routine staff and management interface in such matters as inspection program development, technical assistance contracts, and resolution of both internal policy issues and licensee problems.
During this past y meaningful informaear, DI has increased its ability to collect and evaluate tion about the effectiveness of our programs. While the enclosed narrative represents our best efforts to date, I know that the
' process is not yet at the level to which you and I think it should be.
Nevertheless, I am providing this infonnation to you as being representative cfg y 0307 h
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l DI PROGRAM ASSESSMENT - REGION V Program Assessed: Safety Responsibility 1
The region's initiative in administering a pilot program of loading of sites with more resident inspectors and increased emphasis on team inspections is a primary example of the region's emphasis on safety at operating sites. The assignment of additional residents has increased significantly the amount of inspection hours applied to a facility.
However, the emphasis on resident inspectors may have had some impact on the region's ability to conduct specialist inspections. Also, based on observations by HQs staff, the quality of the team inspections does not appear to match that observed in Regions I or III. On balance, the initiatives in Region V appear to have made a major improvement in the region's focus on safety issues and their ability to address them.
The region has demonstrated a less than expected emphasis on assuring the full implementation of the construction inspection program. At Palo Verde Unit 3 the inspection program is behind schedule, primarily due to a regional manage-i ment decision to defer inspections at Palo Verde 3 because of other inspection resource priorities. As a result, a significant commitment of additional resources has been allocated to meet the projected licensing date.
Program Assessed: Principal Regional Assignments A sample of inspection results for operating reactors indicated acceptable performance of appropriate programs, although there is some evidence of problems in completing inspections in specialty engineering areas such as in-core physics inspections following refueling and containment leak rate inspections.
This could be due to the Region V pilot program of increasing resident resources at the expense of regional speciality resources. Additionally, Region V has requested extensive contractor support funds to supplement regional inspection resources.
In some cases, these requests were in excess of budgeted amounts.
The region has developed and implemented a pilot approach to accomplish the inspection program at San Onofre:
they have assigned four residents (a SRI and one RI for each of the three units). The residents have primary responsibility for the accompl bhment of the Minimum and Basic programs. Their efforts are augmented by team inspections (performed approximately annually). The quality of the team inspection oi3erved at Trojan and. the documented results of the team inspection at San Onofre do not appear to match the quality of the Region 111 team inspections reviewed (Davis-Besse and Palisades) and the Region I "0AT" inspection resulls' reviewed (Maine Yankee and Peach Bottom).
The degree of completion of the construction inspection program for the region was reviewed based on the Palo Verde Unit 3 site. A special assessment was made cf the Palo Verde Unit 3 inspection data, and included visits to the site and the Region V office.
The assessment showed that implementation of the inspection program was behind schedule and some inspection windows had been
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w.. missed.
It was found that the region had made a conscious decision to reduce the inspection efforts at Palo Verde Unit 3 in order to support the licensing of the region's other plants (i.e., Diablo Canyon and WNP-2). The total number of construction inspection hours at Palo Verde Unit 3 is 2900.
The region's review of the inspection program at Palo Verde Unit 3 found the region well below their FY 1985 Operating Plan goal.
The inspection work to be made up has been discussed by regional personnel and extra resources have been budgeted to accomplish these inspections.
Discussions with the region regarding the relatively low number of inspection hours recorded for Palo Verde Unit 3 indicated that there has been an overuse by the region of taking credit on Unit 3 for the inspections performed on Unit 1.
Some credit is allowed by MC2512 for procedure review; however, the use of inspection credit for work observation and records review is not intended.
The region and IE will evaluate the inspection program status to ensure adequate completion of construction inspections.
Region V inspection reports nonnally provide adequate discussions of inspection activity; however, issuance of the inspection reports has not been timely.
Violations and deviations are well documented and are soundly supported.
IE review of the inspection reports, comparisen of site findings, and observation of resident inspector activities showed that the region's inspection practices are consistent with the pr3 gram requirements.
The use of contractor tecimical assistance for construction inspection activities was found to be consistent with IE guidance.
Based on an extrapolation of year-to-date inspection experience, the Region should meet the goal in the regional operating plan of 138 materials inspections in FY 1985.
There is essentially no backlog of overdue materials inspections nor closecuts of expired materials licenses.
Program requirement have also i
been met for the fuel facilities in the Region.
The inspectors for materials i
and fv31 facilities are experienced individuals who have performed quality inspections. Because of the relatively small number of materials licenses in the Region -- many of whom are military licensees with good records of control over use of radioactive materials -- there have been few cases requiring special inspections.
In the fuel facility inspection program, the Region has used health physicists and MC&A specialists as well as the project inspector to ensure that the proper skills were being utilized in the inspection process.
Part of the expertise in the MC&A area has come from the safeguards staff at Pacific Ncrthwest Laboratory. For_t.ransportation and Part 61 inspections, a technically sound program of inspection has been carried out for reactors and fuel facilities.
There was a delay of several months in getting new transportation and Part 61
,' inspection procedures to the materials and fuel facility inspectors. However, regional supervision acted promptly when it was informed of that problem and ensured that each inspector received the new procedure.
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