ML24057A243

Resident Inspector Program Overview

ML24057A243
Person / Time
Issue date:	02/22/2024
From:	Sarah Obadina NRC/NRR/DRO/IRIB
To:
References
Download: ML24057A243 (5)

Text

Resident Inspector Program Over view

HISTORY OF THE PROGRAM

In June of 1974, the Atomic Energy Commission (AEC) established a trial resident inspector program to provide onsite veri"caon of licensee compliance with regulaons. Prior to that, the inspecon program relied on inspectors located at regional oces to carry out porons of the inspecon program, such as "re protecon, plant security, and quality assurance (QA). Due to the associated administrave burdens (e.g., travel me, inspecon preparaon and documentaon) only a fracon of the inspectors me was spent at the site. In addion, a majority of the inspectors me was focused on records review instead of observaon of work acvies in the "eld1 . Regulatory sta were also concerned about licensee quality assurance programs. As one AEC sta member noted, ulies, rather than viewing QA as an essenal part of plant management, too oen merely met the minimum requirements mandated by the AEC2 .

The AEC established the resident inspector program on a trial basis at the Kewaunee and Point Beach nuclear power plants. The resident inspector program connued aer Congress passed the Energy Reorganizaon Act of 1974 that broke up the AEC and established the Nuclear Regulatory Commission on January 19, 1975. The trial program ended successfully in October 1976, and in 1977, the NRC expanded the program to more facilies2. Soon aer implementaon, Three Mile Island Unit 2 experienced a serious accident that led to a paral meltdown and small osite release of radioacvity8 in March of 1979, which damaged public percepon of nuclear energy and changed the NRCs oversight of nuclear power plants. As a result, the NRC expanded the resident inspector program from one to at least two onsite inspectors. By the end of 1979, 60 resident inspectors were staoned at 45 nuclear power plants7. In 1988, the NRC adopted the N+1 resident inspector stang policy, w here the policy required one more resident at a site than TMI Unit 2 control room during crisis in 1979 the number of units.

In 1999, NRC sta re-evaluated the N+1 stang policy to ensure eecve and ecient use of inspecon resources. In its evaluaon, the NRC sta noted that, over the last decade, the nuclear industry s average safety performance had steadily improved. The NRC sta determined that it was no longer necessary to have addional resources to conduct plant speci"c inspecons at all sites due signi"cantly improved industry performance. As a result, the NRC sta recommended revising the resident inspector stang policy to require two resident inspectors at single and dual unit sites and three resident inspectors at triple unit sites11. The NRC commission approved the s t a s recommendaons in January 200014.

BACKGROUND

Each commercial nuclear power plant in the United States has at least two resident inspectors that are responsible for monitoring the day-to -day operaons at an assigned facility. They serve as the eyes and ears of the agency. Resident inspectors typically live in the community of their assigned plant.

Some of the daily acvies include obtaining status of the plant by atending plan of the day and shi turnover meengs, performing control room walkdowns and independently verifying plant parameters, interviewing licensee personnel, and reviewing operator logs. The resident inspectors share the informaon, every morning, with the regional oce. To priorize inspecon of risk signi"cant acvies, inspectors review the licensees schedule of acvies for the day. Based on that review, the inspectors will determine which acvies (e.g., maintenance, tesng, or other evoluons) to observe in the "eld. Inspectors also perform plant walkdowns. During plant walkdowns, they evaluate overall status of equipment in the plant including general material condion.

If an inspector iden"es a plant issue such as a degraded condion or de"ciency, they will nofy the licensee. Depending on the signi"cance of the issue, inspectors may document a "nding or violaon.

These issues, as well as other inspecon acvies, are documented in quarterly inspecon reports that are publicly available and are communicated to the licensee during exit meengs.

One of the most important roles of a resident inspector is event response. Resident inspectors are on call 24/7 to respond to issues such as plant trips, equipment failures, or an external event (e.g., loss of osite power). They evaluate the licensees acons and report the informaon to the regional oce.

During these events, inspectors must perform sucient inspecons to develop an independent assessment of plant condions, which provides essenal input to senior management to use in determining the NRCs response to an event9. Another responsibility of resident inspectors includes receipt and roung of allegaons. An allegaon is an issue related to NRC acvies where the validity of the issue is unknown. Allegaons can come from a variety of sources such as licensee personnel, contractors, or members of the public. Resident inspectors document the concerns and forward them to regional specialists to determine appropriate acons .

Resident inspectors also take the opportunity to communicate with members of the public during annual assessment meengs or community events. The annual assessment meengsare public meengs to discuss the performance of an assigned nuclear power plant.

Community events allow inspectors to let the public know they ex ist and discuss their role as inspectors.

Aer establishment of the resident inspector program, one issue of concern that developed was related to an inspector s objecvity. Speci"cally, in a report accompanying the NRC authorizaon bill for "scal year 1979, the House Commitee on Interstate and Foreign Commerce noted that placing an NRC employee at an operang nuclear power plant could lead to familiarity with the licensee and impair the inspector s objecvity 1. The NRC addressed the concern by liming the tour of duty at a site and strengthening the code of conduct for inspectors11. Currently, the tour length for resident inspectors at an assigned nuclear power plant has been restricted to 7 years. Residents are also expected to complete at least a week of inspecon at another site every year to enhance objecvity 6. For code of conduct, IMC 1201 provides guidance to employees that perform inspecons. One restricon is associated with avoidance of appearances of loss of imparality. Speci"cally, employees must consider whether certain circumstances would raise a queson of their imparality in the performance of their ocial dues. In addion, resident inspectors are discouraged from parcipang in social acvies in which plant employees are involved and are prohibited from accepng gis from prohibited sources (e.g., licensee or contractor employees)15.

RESIDENT INSPECTOR DEVELOPMENT PROGRAM (RIDP)

To w a r d s the conclusion of the trial resident inspector program in 1976, the NRC requested comments from licensees on the implementaon of the program. Kewaun ee noted a successful program but communicated a reservaon associated with inspector quali"caons. Speci"cally, Kewaunee stated that

[i]f the inspectors in a future Resident Inspecon Program are selected according to a strict standard which requires previous operaonal experience and broad based knowledge of operang plant acvies, the program should be advantageous to both the NRC and the Licensees; however, if such Resident Inspectors are not quali"ed by previous extensive experience in operang facilies, the program will be ineecve and burdensome4 . In March 1980, the NRC submited a report to Congress on the status of the resident inspector program. In its response to the report, Congress raised a concern that individual resident inspectors may lack the breadth of technical knowledge to oversee the full range of acvies involved in the construcon and operaon of a nuclear power facility. To address the concern, the NRC developed inspector quali"caon requirements11.

The current quali"caon program is designed to ensure the development of competency in four general areas: (1) legal basis and regulatory processes, (2) technical experse, (3) regulatory pracces, and (4) personal and interpersonal eecveness13. Within several months, depending on previous educaon, training and experience, a candidate in the RIDP can become basic inspector quali"ed, where limited scope inspecon acvies under an appropriate degree of supervision may be performed12. The second level of the quali"caon process is the pro"ciency level, which is composed of general and technical pro"ciency acvies. The general pro"ciency acvies are designed to develop interpersonal and inspecon skills, and the technical pro"ciency acvies are designed to develop technical experse and provide the tools needed to evaluate informaon, analyze data, and apply NRC rules and regulaons. The "nal acvity is to complete a quali"caon board, where a candidate will be evaluated on how well they can integrate and apply inspector competencies to "eld situaons. Typically, a mock board can be used to prepare the candidate for the "nal quali"caon board10.

Candidates in the program have the opportunity to learn from experienced inspectors as well as atend training at the NRCs technical training center as they work to develop necessary competencies. Aer obtaining full inspector quali"caons, inspectors are expected to build on what was learned during inial training as well as keep up to date on changes to the inspecon program. Inspectors are encouraged to expand their technical knowledge10.

50TH ANNIVERSARY

Over the 50 years that resident inspectors have been assigned to nuclear power plants, they have directly contributed to plant s afety. For example, on September 3, 1980, Arkansas Nuclear One, Unit 2, had to shutdown aer the NRC resident inspector discovered that the service water "ow rate through the containment cooling units did not meet the technical speci"caon requirement. The licensee determined the cause to be extensive "ow blockage by Asiac clams. The NRC determined the blockage represented a generic problem of safety signi"cance, and it issued a bullen to all licensees16. In another example, resident inspectors iden"ed that scaolding was in direct contact with safety related piping and documented a violaon due to the licensees failure to maintain the required clearance between scaolding and safety-related piping20. As a result, the licensee revised their scaold control procedure to provide addional guidance on the need for adequate bracing to prevent scaolding from moving during use17. Similarly, resident inspectors iden"ed that the high-pressure core injecon (HPCI) booster pumps outboard bearing oil level was below the minimum operang level and the housing was acvely leaking. The inspectors documented a violaon and as a result the licensee restored the proper oil levels, repaired the leak, conducted training for equipment operators, and performed observaons of equipment operator rounds19. These examples represent a few of the many instances where resident inspectors had a posive impact and contributed to the NRC s safety mission.

REFERENCES

1. ML033630017, NRC Needs Alternave to Mandatory Relocaon For Maintaining Objecvity Of Resident Inspectors, Report to the Chairman, U.S. GAO oce , November 2, 1983.

2. A short history of nuclear regulaon 1946-2009, NUREG/BR-0175, Revision 2, October 31, 2010.

3. ML19329B699, Leter from NRC to Davis -Besse Nuclear Power Plant, March 19, 1975.

4. ML111650821, Kewanee Comments on the Implementaon of the Resident Inspecon Program, July 14, 1976.

5. ML19326C109, Leter from NRC to Arkansas Power and Light Company , May 16, 1978.

6. IMC 0102, Oversight and Objecvity of Inspectors and Examiners at Reactor Facilies, April 24, 2013

7. NRC Annual Report - 1979, NUREG-0690 , January 1, 1980.

8. ML040280573, Backgrounder on the Three Mile Island Accident, January 28, 2004.

9. IP 71153, Follow up of Events and Noces of Enforcement Discreon, September 16, 2020.

10. IMC 1245, Quali"caon Program for Reactor Inspectors , May 15, 2023.

11. SECY-99-227, N+1 Resident Inspector Stang Policy , September 13, 1999.

12. IMC 1245 App A, Basic-Level Training and Quali"caon Journal , April 11, 2023.

13. IMC 1245 At 1, General Overview of the Inspector Training and Quali"caon Program, May 15, 2023.

14. SRM-SECY -99 -227, N+1 Resident Inspector Stang Policy , January 11, 2000.

15. IMC 1201, Conduct of Employees , July 29, 2016.

16. GL 8 9-13, Service Water System Problems Aecng Safety-Related Equipment , July 18, 1989.

17. IN 2007-29, Temporary scaolding aects operability of safety-related equipment , September 17, 2007.

18. IN 2018-07, Pump/Turbine Bearing Oil Sight Glass Problems, June 13, 2018.

19. ML101250642, Hope Creek Generang Staon - NRC Integrated Inspecon Report 05000354/2010002, May 5, 2010.

20. ML061160574, Moncello Nuclear Generang Plant NRC Integrated Inspecon Report 05000263/2006002, April 26, 2006.