ML20151L029
| ML20151L029 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/1985 |
| From: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20151L006 | List: |
| References | |
| FOIA-88-42 NUDOCS 8507100091 | |
| Download: ML20151L029 (5) | |
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[p *<c ,Iog UNITED STATES
!' , ,. g NUCLEAR REGULATORY COMMISSION
- E WASHINGTON, D. C. 20555 a.,
"% ,',,,, June 26, 1985 MEMORANDUM FOR: Richard W. Starostecki, Director Division of Reactor Projects, Region I Stewart D. Ebneter, Director Division of Reactor Safety, Region I Thomas T. Martin, Director Division of Radiation Safety and Safeguards, Region I FROM: James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ASSESSMENT OF IMPLEMENTATION OF REGIONAL INSPECTION PROGRAMS ADMINISTERED BY THE DIVISION 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 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 !, ALP activities.
- Routine staff and management interface in such matters as ,
inspection program development, technical assistance contracts, I and resolution of both internal policy _ issues and licensee '
problems. ,
During this past' year, DI has increased its ability to collect and evaluate meaningful information about the effectiveness of our programs. While the l enclosed narrative represents our best efforts to date, I know that the l 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 Qp# $['6%2 1 QWH oc o4) gp g,, ._
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Regional Division Directors June 26. 1985 of the perceptions 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.
Oristaal stamed by:
James G. Portlow Janes G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement
Enclosure:
Regional Assessment !
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9 DI PROGRAM ASSESSMENT - REGION I Program Assessed: Safety Responsibility Implementation and usa of effective Operational Assessment Team inspections has contribred sign). 'antly to assuring safe operations at power reactor facilities. Regional initiative and support in such areas as using PRAs to improve inspection approaches, timely accomplishment of Appendix R safe shutdown inspections, and staffing sites with highly qualified resident inspectors clearly demonstrates a strong safety errphasis. The region has demonstrated a high regard for assuring the quality of construction of its assigned facilities i and in the timely implementation of the inspection program. The region has been perceptive and sensitive to safety issues and has taken appropriate treasures to assure effective corrective actions. Special efforts in managing the NDE van inspection program and the emphasis on independent measurements are indicative of the region's concern for safety.
Program Assessed: Principal Regional Assignments A sample of inspection results for operating reactors indicates full perfonnance of appropriate programs. Based on accompaniments and regional visits, Region I took the lead in implementing followup inspection efforts for generic letter 83-28 and provided coments for incorporation into a revised TI. Region I has provided substantial support for inspection program development. They have taken the lead in fonnulating PRA application to the inspection program and strongly supported HQ efforts on "important to safety" site visits. The region made significant efforts to implement Appendix R compliance inspections in accordance with HQ policy. SALP meetings observed by HQ were conducted in accordance with requirements.
Based on programatic reviews and on assessment inspection at Susquehanna, the region had performed ,the operating reactor inspections programs at Susquehanna in an excellent manner. The quality of the associated inspection reports are good. A significant number of supplemental program inspection procedures had been perfonned and the quality of the Susquehanna SALP report was judged above average.
Although a regional assessment has not been completed for the Maine Yankee PAT, a preliminary assessment indicates effective program implementation. In particular, the perfonnance of an Operational Assessment Team (0AT) inspection at Maine Yankee in 1984 appeared to provide a comprehensive, in-depth assessment of operations, quality assurance, procurement, maintenance, and surveillance.
The OAT inspection provided a valuable backup to the regular inspection program.
A fonnal evaluation of the NRC TLD network was administered by Region I indicated that the program was being conducted in a satisfactory and efficient manner.
Some weaknesses were noted in training and procedures need to be developed for the program.
The region demonstrated initiative in instituting several new concepts in the HP and safeguards inspection programs. However, some of these new concepts were instituted prior to identifying them to the program office and obtaining agreement on the level of effort involved. Specifically, the new inspection of water chemistry analysis programs, dosimetry processing programs and security force performance testing inspections are examples where the program office learned of the efforts after they had been initiated. IE is now developing these concepts.
Based on a review of the implementation of the construction inspection program at Millstone Unit 3, the region has generally accomplished the inspection program, taking into account the status of construction of the site except for a few areas. The total construction inspection hours (7000) are ccmparable to other single unit sites and are considered reasonable and balanced.
Inspection reports were found to contain a sufficient level of detail on issues and showed adequate technical content and judgment. However, more timely issuance of inspection reports should be emphasized. A sample of inspection ,
reports for construction and operations showed an average of 45 days to issue an inspection report. The sal.P reports for the past two years showed general agreement with the conclusions of the CAT inspection at Millstone. The region showed perceptiveness in identifying the potential negative trends prior to I their becoming major issues.
Based on an extrapolation of year-to-date experience with the perfonnance of materials inspections, the region should exceed the goal of 940 inspections by the end of the fiscal year. The backlog of overdue inspections has been reduced from 273 to about 80. Also the backlog of expired materials licenses requiring closecut actions has been reduced from 135 to about 70 cases. Special inspections have been conducted as needed in response to allegations and licensee-reported events. For example., the Region promptly responded to problems identified at Syncor and Nuclear Pharmacy facilities in Region I!! by making inspections of facilities owned by the same licensees in Region I.
Regarding transportation of spent fuel, the Region has properly balanced the concerns of the states with the need to conserve inspection resources and has done an exemplary job of monitoring shipments of spent fuel from the West Valley, New York facility to licensee sites. Materials inspectors have devoted little attention to inspections against the 10 CFR 61 radioactive waste requirements I and the quality of materials transportation inspections needs some improvement. l This area has been discussed with regional management and corrections initiated. l The quality of transportation ana 10 CFR,61 radioactive inspections at reactors has been adequate and completed as required by the IE Inspection Manual.
I At fuel facilities, the planned program of inspection has been carried out in l
' substance but the necessary technical skills have not been utilized in certain aspects of the program until late in the appraisal year. For example, there ,
had been only one inspection in a 1-year period at fuel facilities in the Region by a health physics inspector although the subject area was included in
3-inspections by the generalized project inspector. The material control and accounting inspections during nine months of the appraisal year have been conducted by generalists who lacked the needed technical skills in statistics and chemistry. Regional management has acted to provide more health physics expertise in fuel facility inspections and has utilized a chemist from its staff and a statistician from Region II to upgrade the technical quality of MC&A Inspections.
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