ML20151L024
| ML20151L024 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20151L006 | List: |
| References | |
| FOIA-88-42 NUDOCS 8507100054 | |
| Download: ML20151L024 (4) | |
Text
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UNITED STATES p
'g NUCLEAR REGULATORY COMMISSION l
WASHING TON, D. C. 20555 June 26, 1985 MEMORANDUM FOR:
Charles E. Norelius, Director Division of Reactor Projects, Region III R. Lee Spessard, Director Division of Reactor Safety, Region III John A. Hind. Director Division of Radiation Safety and Safeguards, Region III FROM:
James G. Partlaw, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ASSESSMENT OF IMPLEMENTATION OF REGIONAL INSPECTION PROGRAMS ADMINISTERED BY THE OtVISION OF INSPECTION PROGRAMS,(DI/IE)
The enclosure to this memorandum contains a program assessment of regional inspection activities over the past year in those areas administered by this Division. The assessment attempts to bring together both the quantitative and subjective infonnation 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.
1
- Routine staff and management interface in such matters as ins.pection program development, technical assistance contracts, and resolution of both internal policy issues and licensee problems.
Ouring this past~ year. 01 has increased its ability to collect and evaluate meaningful information 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 information to you as being representative fd2 /P P TedY.L O$o7/MOSC/ Q L
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i Regional Division Director <
-2 June 26, 1985 of the 3erceptions which have been consolidated from numerous DI staff inputs.
I ask t1at you review this report and feed back to me ways in which the process can be improved. Not unlike our own licensee inspection program, our sample size is relatively small and perceptions may or may not truely represent the real situation.
Origime.:. sisnee by:
James G. Partlow James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Regional Assessment DISTRIBUTION:
DCS DI Reading JGPartlow Reading JHTaylor RHVollmer ELJordan BKGrimes JAxel rad JLBlaha PFHcKee RFHeishman LCobb IE:DIR/
JGPartio esp 6/13/85 I
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DI PROGRAM ASSESSMENT - REGION III Program Assessed: Safety Responsibility The region has demonstrated effective use of team inspections to focus on and correct problems at operating facilities.
Strong regional initiatives in developing and testing a trial inspection program at two operating sites, implementing Appendix R safe shutdown inspections, and followup of PAT and CAT inspection findings are indicative of the staff's recognition of safety as their dominant responsibility.
The cooperation and willingness of regional staff to accept constructive comments from HQs is a further example of the region's emphasis on safety.
The region has shown a high degree of management concern and attention to the implementation of the construction inspection program. The region has demonstrated an awareness of the current status of inspections and has utilized the information to allocate inspection resources.
The region has recognized and adjusted to the extra manpowe' demands of the Braidwood site wnile providing resources to support other NTOL facilities.
Programs Assessed: Principal Regional Assignments A sample of inspection results for operating reactors indicated full performance of appropriate programs.
The region has been outstanding in their efforts to support program change reviews, SALP working group activities, and fire protec-tion steering comittee efforts.
In particular their work on preoperational inspection procedures was outstanding.
Region III adequately implemented the Minimum and Basic 2515 Inspection Program at Davis-Besse. Of note was the region's use of very effective team inspections to assess QA and Training. These team inspections perfonned many Supplemental Program IPs as well as the Basic Program IPs.
The Davis-Besse SALP (most recent) was more negative than the PAT report.
It appeared to the PAT inspectors that the five SALP Category three grades given by the region to Davis Besse could not be justified based on PAT findings.
The implementation of the inspection program for the Perry 1 site was evaluated and indicated that the region perfonned a generally balanced and comprehensive inspection program. A total of 6040 inspection hours in the construction area (39% for independent inspection and followup activities)_were recorded for Perry 1.
However, some. areas were found not to have received the amount of inspection time as other similiar plants. Discussions with the region showed proper j
.. foresight in that they were also evaluating their inspection program at Perry I and had already planned additional inspections to ensure adequate coverage in several areas.
The implementation of the construction inspection program at the Braidwood site was found to be essentially complete. However, one significant inspection procedure was identified to have not been performed. This procedure was in
2 the area of audits of contractors' QA/QC activities. With the various con-tractors used at Braidwood and the major problems in the electrical, mechanical, and HVAC areas, this procedure should have been performed several times as recomended. However, the region has shown exceptional management involvement and initiative in supporting the necessary extra efforts at the Braidwood site, and the region has been instrumental in causing improvements in the utility's QA organization. The numerous meetings with utility management in 1983 caused these changes and produced more comprehensive corrective action programs, including a construction assessment program (BCAP). The amount of inspection time for the last two years at Braidwood was similar to other two unit sites and was considered satisfactory.
Inspection reports are considered to be satisfactory, however, the reports should be issued in a more timely manner.
A comparison of the SALP reports with the CAT findings shows general agreement in most areas, except for pipe supports and restraints. A number of deficiencies in pipe supports and restraints were identified by CAT but an inspection by the region in the same area identified no problems.
The handling of allegations by the region was found in the two instances examined to be satisfactory with regard to timely evaluations and comprehensive responses.
Based on an extrapolation of year-to-date experience with the perfortnance of materials inspections, the Region should meet the goal of 1,013 inspections by the end of FY 1985. The backlog of overdue materials inspections has been reduced from about 55 in FY 1984 to about 20 this fiscal year. The backlog of expired licenses that have not been closed out within six months has been reduced from about 65 last year to about 20 this year.
The high productivity in accomplishing routine materials inspections has been attained despite the large amounts of staff time required to handle such cases as the J. C. Haynes arrest and facility-decontamination effort and the Nuclear Pharinacy falsifica-tion-of-records case. These regional responses have been timely, technically superior, and have dealt with the public and governmental authorities in a manner that brings credit to the NRC.
In the area of Part 61 low-level waste inspection, the Region made a special effort at reactors during the first year of the regulation to ensure that each facility had an adequate program for carrying out the performance requirements of the new ;egulation. Transportation inspections have been carried out in a technically sound and competent manner.
At fuel facilities the established progra,n of. inspection has been completed.
An example of the high quality of the inspection and evaluation effort at these facilities is th.e case involving employee uptake of uranium dust at the Allied Chemical plant. To ensure quality material control and accounting inspection
.. the Region had made a special effort by securing specialists from outside the Region to help with the inspections since the Region has only a fractional FTE to use on MC&A inspections.