ML20216G247
| ML20216G247 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1998 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Dicus G, Mcgaffigan E NRC COMMISSION (OCM) |
| References | |
| REF-10CFR9.7 SECY-97-285-C, NUDOCS 9804200078 | |
| Download: ML20216G247 (2) | |
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"?,&,, UNITED, r n uMEM "o REISSUED 3/19/98
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See attached comments.
.. [. g h coMM ss oNER Shir %y Ann fackson COMGJD-98-001/
3/6/98 MEMORANDUM TO:
Chairman Jackson COMEXM-98-002 Commissioner Diaz g
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((h Edward McGaffigan, Jr.('Q W'(N' Greta Joy Dieus FROM:
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SUBJECT:
SECY-97-285 - DISCUSSION OF RESIDENT INSPECTOR DEMOGRAPHICS AND THE BALANCE BETWEEN EXPERTISE AND OBJECTIVITY Having read the information provided by the staff in SECY-97-285, we have concems regarding the apparent continuing decline in the numbers, and level of experience, of our resident inspector staff. The data depict a deteriorating experience base in our current resident inspector staff which can not be allowed to continue.
The Commission has histMcally and publicly placed great reliance on resident inspectors in their day-to-day knowledgeable observation of power plant operations, in their experienced regulatory oversight of maintenance, testing, and corrective actions, and in their site expert;se during events. They have correctly been called "the eyes and ears of the Agency." Proposed budget reductions for regional inspections in FY 1999 and FY 2000 and the notional new integrated assessment process provided to the Commission on January 29,1998 will only enhance the importance of the resident inspectors' role in the Agency.
Concem over the potential erosion in resident inspector training and experience was the source of a 1983 GAO recommendation, originally agreed to by the NRC, not to mandate a maximum resident inspector tour length. In 1988, however, the NRC implemented maximum tour lengths of five years for its resident inspectors, an action that resulted in renewed Congressional interest. In replying to inquiries regarding the attrition rate of its resident inspectors, high national inflation rates and mortgage rates were cited as factors in a then-high attrition rate of 17 percent per year. SECY-94-181 detailed problems in resident attrition (then at 11 percent per year), included statistical data in a format similar to that presented in SECY-97-285, and listed intended plans for addressing the issues identified. It now appears that the measures implemented have not been successfulin abating the excessive resident attrition rate.
We suggest that the staff establish a standard demographic format to report to the Commission on resident demographics using the following guidelines. First, the use nf arithmetic averages alone has a potential weakness, since a few long-time resident inspectors could skew the total resident time and site time data. The staff should also use median values when reporting resident time, site time, and NRC experience. Second, including non-qualified inspectors in the experience data is hard to defend. The resident time and site time data should only include qualified resident inspector time as a measure of experience. Third, we note that SECY-97-285 referenced non-NRC nuclear power plant experience in mitigation of tne large numbers of "new hires" in the resident program. We believe this data (relevant non-NRC experience) shoula be in the demographic comparison especially as it relates to new hires. While it may be difficult to
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Chairman Jackson's Comments on COMGJD-98-001/COMEXM-98-002 The Commission places a great reliance on direct inspection, and in particular on the efforts of resident inspectors. Given the likelihood of continuing dependency on direct inspection results-whether under the current inspection program or as part of the proposed integrated msessment process being developed (Integrated Review of Assessment Processes (IRAP)-
the quality and expertise of resident inspectors likely will continue to play a critical role in ensuring that nuclear power plant licensees meet their responsibilities for safe facility operation.
i However, given the number of ongoing reviews in this area, I believe we may be premature in drawing conclusions about current resident inspector demographics, as well as in determining what data should be included in an annual report to the Commission. The staff has completed a job task analysis of regional Divisions of Reactor Projects, and is in the process of completing a job task analysis for the NRR Division of Reactor Projects. The staff also is developing enhanced information management and information technology tools for reactor licensee assensment. One clear objective of these efforts has been to reduce the administrative workload ori resident and regional inspectors, and to increase the availability of resident inspectors for direct inspection time through increased process efficiency. Perhaps most significant is the IRA, which could have significant implications for the inspection program as well as for enforcement and long-term assessment.
I believe it is only logical that we should answer certain questions in sequence: (1) What is it that we want to accomplish? (2) What is the program that will enable us to reach those accomplishments? (3) What resources-including human resources--does this program i
require? and (4) What demographic data should we be analyze-and at what periodicity-to ensure that we are securing the necessary human resources-including resident inspectors?
Within that overall context, I support the need for regularized updates on the effectiveness of our inspection program, as well as the need to establish measures of this effectiveness.
However, as outlined above, I believe that any demographic data '.iust be placed in a context.
That context, in my view, is still being shaped by ongoing studies, and in particular by the IRAP, which is most directly focused on providing answers to Questions 1 and 2 of the preceding paragraph. Therefore, I do not believe that current staff efforts will be improved on by requesting that recommenhtions on the resident inspector program be made by an earlier deadline.