ML20198E479
| ML20198E479 | |
| Person / Time | |
|---|---|
| Issue date: | 11/16/1992 |
| From: | NRC OFFICE OF POLICY PLANNING (OPP) |
| To: | |
| References | |
| OPP-92-1, NUDOCS 9212070233 | |
| Download: ML20198E479 (21) | |
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UNITED STATES 5
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NUCLEAR REGULATORY COMMISSION i
WASHINGTON, D,c, 20666 s
November 30, 1992 t-4
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Attached is a copy of a report to be placed in-the system.
The PDR has been provided an advance copy.,
Thank you.
Barbara'Tompkins Office of Policy Planning 504-3600 i-m.
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OFFICE OF POLICY PLANNING ASSESSMENT OF TIIE REACTOR INSPECTION PROGRAM OPP-92-01 November 16,1992 kB REGy es s
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1 EXECUTIVE
SUMMARY
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The Executive Director for Operations (EDO) directed the j
offices of Policy Planning (OPP) and_ Nuclear Reactor Regulation i
(NRR) to conduct a broad review of the reactor inspection program, focusing on the overall health and effectiveness of the l
pr agram and its assessment and management process.
This report responds to that direction by providing a broad perspective on 1
(1) the impact of the inspection program on the safety performance of nuclear utilities, (2) the effectiveness of inspection program elements and regulatory initiatives such as j
the systematic ~ assessment of licensee performance (SALP) and the problem plant list, and (3) those policy initiatives that are appropriate to enhance the effectiveness and management of the inspection program.
l The broad perspective called for by the EDO led to an effort that combined a review of relevant program and implementation j
documents with focused interviews of selected utility executives, staff members of the Ir.atitute of Nuclear Power Operations i
(INPO), and NRC regional and headquarters managers.
During the j
interviews, the following questions were addressed:
i Are-the objectives of the inspection program met?
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How does the inspection program affect utility safety j
performance?
1 Which regulatory performance initiatives'are most effective?
Are inspection program benefits commensurate with agency j
expenditures?
i Is the balance of safety and performance versus. compliance e
appropriate?
l Are feedback and lessons learned used effectively?
The overall conclusion reached is that the reactor inspection program lis healthy and has a positive impact on the safety performance of utilities.- However, opportunities exist-l for making improvements in the effectiveness of both the-inspection program'and the regulatory initiatives founded on inspection program results and conclusions.
These improvements would enhance the program's focus-on safety significance:and diminish the regulatory burden.
They could be implementedLwith minimal resource commitments.
The body of this report provides l
the findings from which this overall conclusion.is drawn and the-l specific recommendations for improvements, both of which are summarized below.
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Assesunent of the Reactor inspection Prooram ill Finding Recommendatio.n The objectives of the No recommendation in this inspection program are being area.
met.
The inspection program has a No recommendation in this positive impact on safety area.
performance at utilities.
Team in pections have a Revise inspection procedures substantial positive impact on and practices, addressing both utility safety elements described in Appendix performance and resource A,
to enhance definition of expenditures.
- However, issues, acceptance criteria, inspection practices that and NRC preparation before promote both the positive inspection.
safety impact and an efficient use of NRC and utility resources are not consistently applied.
The resident program is Establish N+1 resident working well and specialist staffing as a policy guideline inspections are important to only.
SALP and senior management meeting (SMM) considerations.
Discretionary specialist resources are already at a low level and implementation of N+1 will further reduce ability to tackle emerging issues.
The problem plant list is Notify chief executive officer highly effective in focusing or board of plant performance proper attention on poor plant that extrapolates to problem performance.
Most licensees plant status.
Category 2 would initiate robust actions plants should have minimum to avoid problem plant status.
residence time on the list However, once on the list, (e.g., 12-18 moaths) before attention from NRC, INPO, and they are considered for insurance carriert, along with removal.
the utility's desire to be removed from the list quickly, results in heavy and some unproductive resource expenditures.
Assessment of the Reactor Insoection Proaram iv Finding Recommendation SALP provides effective No recommendation in this regulatory communication with area.
utility boards, management, and the public, and is useful for planning and motivation.
The inspection program yields Make inspection program more benefits cosaensurate with responsive to identified needs agency expenditures with focus for adjustment based on safety and resources near appropriate considerations, and increase level; however, there are use of risk assesement to opportunities for improvement, focus inspections.
particularly where the inspection activity is without a clearly identified nexus to reactor safety.
The focus on safety and Institute measures to enhance performance versus compliance review of inspection findings appears appropriate.
for which licensee action is Opportunity exists for expected.
improvement in measures to ensure consistency of performance-based findings.
Escalated enforcement is Reduce escalated enforcement effective as an attention focus in areas where safety getter but the safety benefit objectives are already met.
does not appear commensurate Simplify the enforcement with NRC or licensee resources
- process, expended.
The inspection program has Revise the process to review improved in response to lessons learned in the feedback and lessons learned, inspection program and to but the process lacks rigor in ensure program improvements.
implementation.
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Assessment of the Reactor Ir}soection Proaram v
i-CONTENTS i
EXECUTIVE
SUMMARY
11 INTRODUCTION 1
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j DISCUSSION 1
l Meeting the Inspection Program Objectives 2
3 Impact on Utility Safety _ Performance...
3 Effectiveness of Regulatory Performance Initiatives 5
Cost Effectiveness-of Inspection. Program.
6 l
Balance of Safety and Performance versus Compliance 7
i Feedback and Lessons Learned.
10 1
i APPENDICES 4
A Elements of an Effective Team Inspection Effort i
B Team Members'Who Participated in the Assessment of the i
Reactor Inspection Program
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An.gssment of the Reactor Inspection Proaram i
INTRODUCTION l
By memorandum dated August 4, 1992, the EDO directed OPP and NRR to conduct a broad review of the reactor inspection program, focusing "on assessing the overall effectiveness and health of the inspection program and its assessment and management process."
To implement this task, a team (see Appendix B) experienced in the inspection program, regional operations, and industry activities was formed and developed an assessment plan.
The team prepared a detailed list of questions and issues to be addressed and selected for interviews seven executives from l
utilities whose nuclear plants represented diversity in plant type, age, and historical performance.
The utilities selected I
incluaed at least one from each of NRC's five regions.
The team also decided on interviewing selected NRR and Office of Enforcement managers responsible for various elements of the inspection and enforcement program, the three top levels of management at NRC Regions II and III, and persons selected by INPO who were experienced in the INPO plant assessment process.
The interviews began on September 4 and were completed on September 25, 1992.
1 The EDO was briefed on the results of this assessment on October 6, 1992.
He requested that the team prepare this report documenting its findings and recommendations.
DISCUSSION i
The EDO instructed the team to provide a "think piece,"
interpreted to mean a high-level, rather than detailed, assessment designed to answer the question of the overall effectiveness and health of the inspection program and to stimulate consideration of and perhaps additional study and initiatives in selected areas.
The team therefore, developed interview questions that were broad and would elicit unfiltered i
and direct responses, and selected interviewees who represented diversity in viewpoint ~and experience.
Although the interviews were sometimes far ranging, there was surprising uniformity of i
agreement in the findings presented herein.
The views of the industry participants on the overarching issue of effectiveness l
and health of the inspection program were generally consistent with those of the NRC participants.
The recommendations presented are either the team's-views or an amalgam from views presented by interviewees that.the team believes will bc beneficial in enhancing the effectiveness of the inspection program.
The subsequent sections of this report are organized to follow the topic areas used in the interviews, which, taken as a 4
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Assessment of the Reactor Insoection Procram 2
whole, are responsive to the charter of assessing the overall effectiveness and health of the inspection program:
meeting the inspection program objectives impact on utility safety performance e
effectiveness of regulatory performance initiatives e
cost effectiveness of inspection program e
balance of safety and performance versus compliance e
feedback and lessons learned Meeting the Inspection Program Objectives Findings The team found strong agreement among utility executives and NRC managers that the overall objective of the inspection program is being achieved.
This objective, as stated in SECY-92-169, "The Staff's Progress on Actions to Improve Independent Assessment of the Inspection Program," is to ensure licensees are operating facilities safely by:
1.
Providing one of several bases for conclusions on both individual licensee and industry wide performance for allocating resources.
2.
Ensuring that the licensee's systems and techniques for conducting internal inspections and maintaining control result in safe operations.
3.
Finding and resolving plant-specific safety concerns that have generic significance.
4.
Identifying significant declining trends in performance and performing inspections to verify that the licensee has resolved the issue before performance declines below an acceptable level.
The role of the inspecti.on program in providing independent oversight of licensee programs and activities to ensure safe
engssment of the Resctor Insoection Prooram 3
operations wss well understood by NPC and industry and considered neceusary by both.
There was good agreement that the inspection program is effective in identifying significant declines in licensee d
performance before that performance declines below an acceptable level.
The process for selectively examining licensee activities generally focuses on the " safety-significant" areas and at the proper depth to provide necessary insights for the staff to draw meaningful conclusions about licensee performance.
The inspection program ensures that licensees' systems and techniques for conducting-internal inspections and maintaining control result in safe operations.
It focuses licensee-managements' attention on ensuring that their internal systems proactively identify potential safety problems and enact lasting corrective actions.
In most cases, the inspection program accomplishes this without usurping licensee managements' responsibilities or prerogatives.
The team attempted to identify tiays to directly measure the effectiveness of the inspection program in achieving'its primary objective of ensuting safety.
Tha NRC and industry use various indicators to gauge safety performance; these include SALP, NRC performance indicators, INPO performance indicators, and accident sequence precursors.
These indicators suggest that industry safety performance has improved.
Because the inspection program is but one of several major influences on licensee performance, including INPO and other industry initiatives, it is difficult to L
quantify the direct contribution of the inspection program.
However, there is widespread agreement that the inspection program, and the regulatory initiatives that are greatly influenced by inspection program results, have sabstantially contributed to improved safety performance by the industry.
RecommeL*ations None.
Impact on Utility Safety Performancee The team found that the NRC inspection program does contribute to long-term safety improvements at nuclear power plants.
Although some NRC inspection contributions are qualitatively distinguishable from other contributors to nuclear safety improvement (such as utility, INPO, and other NRC initiatives), we found no accurate and objective means to separate and quantify all inspection program activities.
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1 Allt11 ment of the Reactor Inspection Prooram 4
The team found that the current NRC inspection program structure is good and provides a generally. effective mix of types of inspection and areas of focus.
This is discussed further in the section entitled " Cost Effectiveness of the Inspection Program."
The team developed a number of insights regarding NRC team inspections and resident and specialist inspections; these are discussed below.
Team Inspections 4
Findings Team inspections are powerful tools and have been especially valuable to enhance the safety performance of licensees.
Safety improvements often preced2 NRC inspections as utilities perform self-assessments in response to NRC's display of interest in an area.
Refinements and improvements to NRC's management of team inspection programs, as well as teams themselves, can further improve effectiveness and perhaps reduce resource expenditures.
i Team inspections involve substantial utility and NRC' 4
resources end thereby warrant commensurate management attention toward maximizing safety benefit and managing the impact on these resources.
We identified a number of elements or features that promote a positive safety impact of an inspection while promoting i
efficient use of NRC and utility resources related.to the team 4
inspection.
These are discussed in Appendix A.
Although most of i
these elements are present to some degree in many team inspections, further staff effort is needed to ensure they are consistently applied to all.
For example, some team inspections have been too large and have lasted too long or have been i
conducted without a clear definition.of the issues and criteria i
for acceptance.
By consciously addressing these elements thoroughly and consistently, NRC could achieve improved quality, better safety impact, more uniform performance, and-better control of the regulatory burden.
Recommendations NRC should ensure that inspection procedures and practices consistently address the elements of an effective team inspection outlined in Appendix A.
This would include more effort to reach 4
an understanding between the NRC and industry on objectives and expectations.
The inspection teams should be-evaluating a plant a
against defined criteria.
Also, stronger measures'are needed to 4
j internally test the validity, significance, and consistency of j
inspection team findings.
Given resource constraints, this process might involve inspecting somewhat less, but expending-more effort in evaluating findings.
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Assessment of the Reactor Insoection Proaram S
Resident and Specialist Inspections Findings The resident inspector program is well received by industry and considered to be working effectively for safety.
Licensees and NRC staff interviewed considered the program to be appropriately staffed and did not believe an increase in resident staffing would enhance safety performance.
They indicated that there is more safety benefit to providing increased resident inspector attention to poorly performing sites than to varying the number of inspectors solely on the basis of the number of units.
Individual specialist inspections provide less dramatic results than team inspections and resident inspector activities; nonetheless, they are important to assessing trends and overall licensee performance.
Thair findings are important contributors to the SALP and SMM process.
In addition to individual inspections, specialists follow up events and allegations and contribute to team inspections.
In some regions, implementation of N+1 minimum staffing will further cut specialist resources, which are already at a low level.
Because the resident inspector program already appears adequately staffed, full staffing at an N+1 level does not seem to be warranted.
Recommendations NRC should establish N+1 as a policy guideline, with a minimum of two inspectors per operating site.
Regional administrators should annually justify to the EDO exceptions to N+1 based on safety benefit.
Effectiveness of Regulatory Performance Initiatives Findings The results of the inspection program provide the principal bases for application of certain regulatory performance initiatives, such as SALP, the problem plant list, and enforcement.
Licensees and, to varying degrees, interested parties inside and outside the industry give all of these initiatives priority attention.
The focus the team put on this issue was that of determining which of these initiatives was the most effective in enhancing licensee safety performance.
Both industry and NRC consider the problem plant list highly effective in focusing proper regulatory and licensee attention on poorly performing plants.
There was general agreement that this is the
essessment of the Reactor Inspection Proaram 6
most certain way to ensure improved safety performance.
Other NRC initiatives, along with INPO, peer, and public pressure are not always sufficient to force those fundamental changes in a utility's operating and management practices that are often necessary for a lasting turnaround.
Strong evidence existed that most licensees would take robust actions to remediate poor performance if they considered their plant close to the problem plant list.
Other evidence showed that it is more difficult, costly, and disruptive to turn a plant around once it is placed on this list.
This is because problem plant status results in overwhelming attention, not only from the NRC but from INPO, insurance carriers, and financial interests.
This, along with a desire to be quickly removed from the list, results in heavy and often unproductive resource expenditures.
The SALP is also considered an effective regulatory tool.for communication with licensee management, utility boards, and the 3
public.
Because many licensees use the SALP'in their planning process, initiatives deriving from the SALP may get long-lasting attention.
The interviewees discussed the unintended'uses of the SALP, such as by the public utility-commissions (PUCs) and the financial community, but no support was shown for current staff initiatives of reducing the number of categories to four.
The utilities interviewed thought that combining certain areas would lessen motivation and accountability.
Recommendations When the SMM process indicates that plant performance extrapolates to problem plant status,'the utility's chief executive officer or board should be so informed.
Should performance continue to degrade, placement on the list could occur no later than the next S}O( meeting.
Further,' Category 2 plants chould have a minimum residence time of,1for example, 12 to 18 months before NRC considers them for removal.
This would allow a more orderly implementation of performance improvements, including management, prograr, and process changes.
The NRC should continue to-closely monitor safety performance to ensure that performance is not continuing to deteriorate, and save major inspection activities for verifying improvement, not validating poor performance.
Cost Effectiveness of Inspection Program Findings This area was one of lively discussion with the utility interviewees because the inspection program is demanding and y......
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Assessment of the Reactor Insoection Proaram
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costly in regard to their resources.
Interviewees believed that certain areas were overinspected and that certain inspection activities focused on areas of low safety significance.
Of those mentioned, the most prominent was security.
Alternatively, we found that NRC's choice of topics for " area of emphasis" inspections, which command substantial NRC and licensee resources, were well received by industry and were cost effective for the agency because of the safety insights gained.
Opportunities for improvement exist, particularly where the inspection activity is without a clearly identified nexus te reactor safety.
By most yardsticks, the general trend in industry safety performance is positive.
The NRC is finding fewer problems; utilities are finding more of their own; performance indicators point to improvement; and, perhaps arguably, public concern about reactor safety has eased.
Therefore, it is not clear that a significant increase in inspection activities would be productive.
In addition, since most of the inspection efforts were viewed as beneficial to safety performance, a substantial cut in inspection activities might have a negative effect on safety.
Overall, the inspaction program yields benefits commensurate with agency expanditure, with its focus and resources near appropriate levels.
Recommendations The most effective use of inspection resources would be focusing attention on issues and activities having high safety significance, recognizing that certain inspection activities are needed as a matter of policy and for increased public assurance.
It appears that the inspection program could be more responsive to diminished safety return in certain areas.
Therefore, the inspection program should make increased use of risk to focus its activities and identify and enact improvements based on safety need.
The SMM process should continue to provide broad direction on changes in prog am emphasis.
Balance of Safety and Performance versus Compliance The findings in this area are organized into two subtopics:
inspection and enforcement.
Inspection Findings The inspection program objective of ascertaining both safety and compliance is well understood, as is the policy that inspectors are safety inspectors first.
NRC's focus on l
Assessment of the Reactor inspection Proatam 8
performance and safety relative to compliarce continues to increase *.nd the overall balance appears appropriate.
- However, safety and performance inspections are more difficult to conduct than compliance-based inspections.
Key chcIlenges involve (1) how to ensure a consistent yardstick is used when compliance is not the measure and (2) how to ensure findings are both valid and sufficiently significant to warrant licensee effort and resources.
For example, comments made in a draft inspection report or at an exit meeting with a licensee may amount to suggestions or criticism of minor safety significance and may receive little NRC review for validity, consistency, safety significance, or subsequent followup.
But the licensee will often put forth considerable effort to address the comment in order to demonstrate responsiveness to the inspection results.
We found that this issue is recognized and is receiving NRC attention but more should be done.
Recommendations NRC should institute better measures to ensure consistency in all NRC inspection findings before the licensee is informed and initiates corrective action.
In particular, the following actions would be apprcariate:
more involvement of management (above the lead inspector or team leader) in the review of inspection findings peer and technical review branch test of significant findings which are likely to result in resource expenditures by the licensee expanded exit preparation to ensure validity of findings o
before triggering substantial licensee effort Enforcement Findings Although escalated enforcement activities capture top licensee management attention, they affect safety much less broadly than the SALP or the problem plant list.
The safety benefit does not always appear commensurate with NRC or licensee resources expended.
The key benefit of escalated enforcement is getting top management attention when needed, but the enforcement process is not solely based on that objective.
For example, many civil penalties (cps) involve self-identified issues to which licensee management is already devoting significant resources.
- Further, in cases of significant compliance-based safety issues, the NRC staff resolves those issues promptly; therefore the enforcement,
Assessment of the Reactor Inspection Prcoram 9
albeit handled expeditiously, usually involves issues which are already well understood by the parties.
Escalated enforcement does not affect licensee planning and resource allocation as broadly as do the SALP and the SMM.
Utility executives do not make key planning decisions based on the likelihood of incurring cps.
On the other hand, SALP and SMM results cause licensees to develop or modify forward-looking, integrated plans and to evaluate overall resource allocations.
Escalated enforcement is not such a factor in management plant.ing and strategy, because enforcement comes from the unexpected.
Publicity is the principal impact on licensees from NRC escalated enforcement.
This impact begins when NRC decides to hold a conference, and is greater for open conferences.
Each action involves multiple publicity opportunities.
Mitigation or escalation of the CP has little affect the utility's concern of damaged public image.
When a contemplated CP is mitigated to zero dollars, there still has been an impact on the licensee, due to the effort and publicity associated with the enforcement conference.
Substantial staff time is spent in developing and revising the packages, which are quite complex and may be confusing to eventual readers.
This factor reduces the ratio of safety benefit to time spent on enforcement.
There is evident frustration within the regions on the cost-effectiveness of enforcement activities.
Recommendations NRC should revise escalated enforcement policy and practices to reduce resources but retain the benefit of seizing top management attention when needed:
Improve self-identification and corrective action credit; for example, make it practical to avoid the enforcement conference.
Focus primarily on corrective action or self-assessment failures.
Evaluate public affairs practices to identify unneeded or redundant issuances, such as followup press releases when cps are reduced.
Licensees may publicize this reduction if they choose.
Simplify the NRC process for developing and approving
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enforcement actions and clarify the regulatory concern and its significance in public material.
Anessment of the Reactor Inspection Prooram 10 Feedback and Lessons Learned Findings Improvements to the inspection program are being made in response to internal feedback, lessons learned, and reactor events.
The staff identifies the need for major inspection enhancements and initiatives through periodic senior management meetings, management and inspector counterpart meetings, inspection program working groups, and the generic communications process.
However, the process is primarily informal and does not routinely invite feedback on necessary program improvements.
The NRC effectively reviews major events and problems for their generic safety implications and provides timely and comprehensive information to the industry, where appropriate, to alert licensees.
The inspection program is a major source of information used in this process.
However, feedback in the other direction, that is, from event insights to the inspection program and procedures to improve future inspections, is less consistent.
Relatively few events or problems result in formal changes in inspection program guidance or requirements.
This may represent a lost opportunity to identify valuable lessons learned.
Inspector feedback on whether major inspections achieved their established objectives and were effective in enhancing safety is not aggressively sought.
In contrast, INPO collects feedback from each peer evaluator and evaluation team member on what was done well and what could be done better.
While this approach is not practical for every NRC inspection activity, it could be applied to major team inspections.
Such a process would potentially improve effectiveness and consistency of these major efforts.
The current process by which individual inspectors provide feedback on necessary program or procedure imorovements is not well understood by the inspectors and is rarely utilized.
The most recent NRC Inspection Manual guidance was issued in 1983 and does not reflect current lines of communication.
Recommendations The staff should revise its current feedback process to provide a more structured one to identify lessons learned and necessary program improvements and enact program improvements.
This process should be simple, establish clear responsibilities, provide for timely change, and provide the following:
review of major events and problems to identify successes and failures of the inspection program l
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Assessment of the Reactor Insoection Prcoram 11 more routine feedback regarding the effectiveness and conduct of major inspection activities ongoing feedback from inspectors as a result of experience t
and insights k
Assessment of the Reactor insoection Proaram APPENDIX A ELEMENTS OF AN EFFECTIVE TEAM INSPECTION EFFORT Developina and Plannina the Effort Develop an overall NRC strategy for dealing with an issue and conduct a management evaluation as to whether a team inspection is an appropriate part of that strategy.
Resolve licensing issues before starting inspections.
Involve industry and establish clear inspection objectives, acceptance criteria, and expectations; resolve any broad differences with industry.
Complete training (on technical areas and inspection techniques) for management, leaders, members of teams.
Provide ample advaace notice to licensees.
Typically, six months or more notice is needed to allow licensees to prudently allocate time and resources to the inspection preparation and support.
Where NRC schedules are tentative or approximate, licensees should nonetheless be notified, rather than having to wait until an exact date is set.
Manaaina the Specific Insocction Effort Control the size and the scope of the team, as well as inspection duration.
Enforce disciplined preparation and other measures to ensure team readiness.
Maintain close rapport with those who know the site (resident and regional personnel).
Carefully select team leaders with demonstrated communication and leadership skills.
Use sufficient and diverse measures to ensure validity and consistency of findings.
(INPO appears to more consistently follow a thorough process to internally test and validate preliminary findings than does NRC.)
Assessment of the Reactor Insoection Prootem Feedback Systematically ensure good feedback to improve subsequent teams.
Use a more graded approach toward inspecting the industry (ranging from large teams and two-week inspections to smaller teams and shorter inspections, specialist inspections, or no inspection as appropriate to situation).
This may save some NRC and licensee resources.
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AH.tument of the Rgaetor insnection Procram APPENDIX B Team Members Who Participated in the Assessment of the Reactor Inspet tion Program Richud H. Vollmer Direct.or, Offico of Policy Planning A. Randolph Blough Chief, Reactor Projects Branch No.
4, Region I Michael R. Johnson Chief, Management and Operations Assessment Section, NRR
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