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Resolution of Generic Safety Issues: Task I.B.2: Inspection of Operating Reactors (Rev. 1) ( NUREG-0933, Main Report with Supplements 1–35 )

The objective of this task was to improve the safety of operations at nuclear power plants by increasing the effectiveness of the NRC inspection program as follows: (1) revise the existing inspection program; (2) implement the resident inspection program; and (3) systematically assess licensee performance so that the NRC could reapportion its inspection resources according to need.

ITEM I.B.2.1: REVISE OIE INSPECTION PROGRAMDESCRIPTION

This TMI Action Plan48 item had the objective of enhancing the safety effectiveness of the operating reactor inspection program. It involved revision of the inspection program to provide more direct observation and independent verification of licensee activities and reduction of inspection documentation. Inspection program revisions focused on the following:

A. Inspections that included, on a sampling basis, such activities as:

(1) Verifying the adequacy of management and procedural controls and staff discipline for the conduct of day-to-day operational surveillance activities.

(2) Independently verifying that systems required to be operable were properly aligned.

(3) Following up on completed maintenance work orders to ensure proper testing and return to service.

(4) Observing surveillance tests to determine whether test instruments were properly calibrated and that approved procedures were followed, including taking equipment out of service during a test and returning it to service after the test.

(5) Verifying that each licensee was complying with the TS and operating parameters by daily control room observations.

(6) Observing routine maintenance to detect such things as the wrong lubricant, improper tightening of valve packing, substitution of unqualified parts, and lack of care in the protection of open systems.

(7) Inspecting the terminal boards, panels, and instrument racks for unauthorized jumpers and bypasses and checking locations against records to ascertain whether jumpers were removed as stated in the records.

B. Reactive efforts in response to operating events, allegations, or followup to previous findings.

C. Periodic Performance Appraisal Team inspections to supplement the resident inspector by an in-depth inspection of the overall plant operation.

D. Intensified inspection program at startup testing.

This item addressed improvements in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.

CONCLUSION

Procedures were issued and implemented to accomplish more direct observation and independent verification, emphasize reactor inspection efforts, and intensify the inspection program at startup testing. Periodic performance appraisal team inspections were functioning and documentation was streamlined.239,247 (For specific procedures, see Chapters 2513, 2514, and 2515 and Part 9700 of the OIE Manual.) All required action on Item I.B.2.1 was completed235,379,406 and this Licensing Issue was resolved with changes in the NRC procedures that addressed the operating reactor inspection program.

ITEM I.B.2.1(1): VERIFY THE ADEQUACY OF MANAGEMENT AND PROCEDURAL CONTROLS AND STAFF DISCIPLINE

This Licensing Issue was evaluated in Item I.B.2.1 above and was determined to be resolved.

ITEM I.B.2.1(2): VERIFY THAT SYSTEMS REQUIRED TO BE OPERABLE ARE PROPERLY ALIGNED

This Licensing Issue was evaluated in Item I.B.2.1 above and was determined to be resolved.

ITEM I.B.2.1(3): FOLLOW-UP ON COMPLETED MAINTENANCE WORK ORDERS TO ASSURE PROPER TESTING AND RETURN TO SERVICE

This Licensing Issue was evaluated in Item I.B.2.1 above and was determined to be resolved.

ITEM I.B.2.1(4): OBSERVE SURVEILLANCE TESTS TO DETERMINE WHETHER TEST INSTRUMENTS ARE PROPERLY CALIBRATED

This Licensing Issue was evaluated in Item I.B.2.1 above and was determined to be resolved.

ITEM I.B.2.1(5): VERIFY THAT LICENSEES ARE COMPLYING WITH TECHNICAL SPECIFICATIONS

This Licensing Issue was evaluated in Item I.B.2.1 above and was determined to be resolved.

ITEM I.B.2.1(6): OBSERVE ROUTINE MAINTENANCE

This Licensing Issue was evaluated in Item I.B.2.1 above and was determined to be resolved.

ITEM I.B.2.1(7): INSPECT TERMINAL BOARDS, PANELS, AND INSTRUMENT RACKS FOR UNAUTHORIZED JUMPERS AND BYPASSES

This Licensing Issue was evaluated in Item I.B.2.1 above and was determined to be resolved.

ITEM I.B.2.2: RESIDENT INSPECTOR AT OPERATING REACTORS

DESCRIPTION

This TMI Action Plan48 item addressed implementation of the approved resident inspector program at operating reactors, as part of efforts to improve safety of operations at nuclear power plants by increasing the effectiveness of the NRC inspection program. Actions included recruiting, training, and assigning resident inspectors to provide a minimum of one resident inspector at each site. Additional resident inspectors were assigned to multi-unit sites. Resident inspectors were also assigned to construction sites with units that were 15% or more complete. This item addressed improvements in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.

CONCLUSION

By June 1980, senior resident inspectors had been placed at all plants awaiting near-term operating licenses to ensure their presence by the time of fuel loading. By December 1980, manning reached 94% of the target level, approximately the highest level that could be expected to be maintained because of vacancies created by losses and the time lag in filling vacancies.239 All required action was completed (see References 235, 239, 333, 334, 379, and 406) and this Licensing Issue was resolved235 with changes to the NRC resident inspector program.

ITEM I.B.2.3: REGIONAL EVALUATIONS

DESCRIPTION

The TMI Action Plan48 described this part of the program to enhance the safety effectiveness of inspections at operating reactors as follows:

The NRC will establish boards in each region to annually evaluate each licensee's performance. The Licensing Project Manager will participate on the board for the facilities he manages. The board will review the enforcement actions, licensee event reports, technical and management performance, significant personnel and organizational changes, licensee safety attitude, and observations by inspection supervisors and inspectors from all cognizant regional disciplines. The results of this evaluation will be documented and used to determine the adequacy of current enforcement sanctions and to redirect, as appropriate, the inspection effort and program plans. In addition, the evaluation will be used to provide a major input into the formal NRC review board discussed in Item I.B.2.4, Overview of Licensee Performance. Meetings with licensee management will be held to discuss board findings as appropriate.

This item addressed improvements in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.

CONCLUSION

Procedures incorporating regional evaluation of licensee performance were issued as part of the NRC Manual Chapter 0516 and all required action was completed.235,239,379,406 Thus, this Licensing Issue was resolved with changes in NRC procedures that addressed regional evaluation of licensee performance.

ITEM I.B.2.4: OVERVIEW OF LICENSEE PERFORMANCE

DESCRIPTION

This item was part of the TMI Action Plan48 program to improve the safety of operations at nuclear power plants by increasing the effectiveness of the NRC inspection program. The TMI Action Plan described this item as follows:

A formal NRC review group (composed of senior NRC personnel from OIE, NRR, NMSS, SD [now RES], as required) will be appointed to provide an overview function of the regional appraisals of the licensees' performance, to determine safety adequacy, and to assess corrective actions planned by regional offices. Based on the findings, the review group will be specifically charged to recommend major enforcement sanctions or license modifications to appropriate office directors. This review group, in addition to receiving inputs from regional evaluations [Item I.B.2.3], will receive inputs from NRR project managers, from NRR technical support program personnel, and from other NRC offices as appropriate. The findings from the board will be made public.

This item addressed improvements in the NRC capability to make independent assessments of safety and, therefore, was considered a Licensing Issue.

CONCLUSION

The formal NRC review group was formed and performed an overview function of the initial set of regional appraisals of licensee performance.298,336 Based on the results of the first set of appraisals, the Commission determined that future assessments should be made at a regional level, that involvement of the other NRC offices should continue as part of the assessment, and that headquarters activity should be redirected to evaluating policy, criteria, and methodology for these assessments.364 Procedures for implementing the Commission's request were subsequently issued as part of NRC Manual Chapter 0516. All required action was completed235,298,379,406 and this Licensing Issue was resolved with changes in NRC procedures to address the overview of licensee performance.

REFERENCES

0048.NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," U.S. Nuclear Regulatory Commission, May 1980, (Rev. 1) August 1980.
0235.Memorandum for H. Denton from R. DeYoung, "TMI Action Plan Items Still Pending," June 10, 1982. [8401170101]
0239.Memorandum for W. Dircks from V. Stello, "TMI Action Plan—Status Report," December 19, 1980. [8205260193]
0247.NUREG/CR-5669, "Evaluation of Exposure Limits to Toxic Gases for Nuclear Reactor Control Room Operators," U.S. Nuclear Regulatory Commission, July 1991.
0298.Memorandum for W. Dircks from V. Stello, "TMI Action Plan—Status Report," April 17, 1981. [8205260194]
0336.NUREG-0834, "NRC Licensee Assessments," U.S. Nuclear Regulatory Commission, August 1981.
0364.Memorandum for W. Dircks from S. Chilk, "Systematic Assessment of Licensee Performance," October 20, 1981. [8210080207]
0379.Memorandum for H. Denton from R. DeYoung, "Draft Report on the Prioritization of Non-NRR TMI Action Plan Items," January 24, 1983. [8401160474]
0406.Memorandum for W. Dircks from R. DeYoung, "TMI Action Plan—Status Report," March 4, 1982. [8204290601]