The industry and the NRC both have roles in providing these controls

and in ensuring that they are maintained. The NRC establishes rules, regulations and guides for the construction and operation of nuclear facilities and for the handling of nuclear materials. Organizations licensed by the NRC must abide by these regulations and are directly responsible for designing, constructing, testing and operating their

facilities in a safe manner. The NRC, through its licensing and inspection programs, provides assurance that its licensees are fulfilling their responsibilities.

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The NRC inspection programs are aimed at determining how well a Combination of programs those of the licensee and contractors working. We make inspections of licensees and of each contractor performng safety-related work, concentrating primarily on those licensee and ontractor efforts associated with systems having direct safety signiicance. Our inspections include a thorough review of each qualityIssurance organization and quality-assurance procedures, review of work control procedures, observation of work in progress and a review of the "ecords of work accomplished. NRC also reviews the qualifications and

training of the work force.

The structured quality-assurance approach for NRC inspection has been

designed to provide for multiple levels of inspection and verification

by NRC, the licensee and licensee contractors (Chart 4). The nuclear inspec

tion activity is pyramided, with each level of activity being verified, inspected or audited by those above. The NRC inspection effort is essentially the apex of this pyramid of inspections and audits. Our effort is the last in a series of inspections by many others, and we apply significantly less resources. Through this technique, a relatively

small verification sampling by the NRC can provide significant insights into the performance of the licensee and contractor programs in assuring the protection of public health and safety.

CURRENT AND REVISED PROGRAMS

The basic philosophy of the current NRC inspection and enforcement program is that the licensees are responsible for safe construction and operation of their facilities (Chart 5). The proper role for NRC is to assure that this responsibility is adequately discharged. As I mentioned earlier, we gain this assurance by concentrating on the management and control systems that the licensee follows in his day to day business. The program that we follow has been carefully derived and has withstood the test of time. It provides an adequate technical basis to assure public health and safety is protected. It can, however, be improved.

As Director of the Office of Inspection and Enforcement, I occasionall hear criticisms of our programs, especially our program for inspecting nuclear power plants. While these criticisms come from a variety of

sources, they generally follow four consistent themes: (1) there are too few NRC inspections; (2) inspectors spend too little time actually at the plant; (3) even when onsite, inspectors spend too much time reviewing paperwork as opposed to observing actual work or observing and conducting tests and measurements; and (4) there is not enough licensee performance evaluation with appropriate NRC response. We evaluated our program this year as part of the broad-based study of inspection and enforcement that I described to you last year. We concluded that a decided move by NRC into more direct verification and independent measurements coupled with program refinements to provide more onsite time, would enhance the base for NRC technical judgments and, at the same time, would effectively respond to those criticisms.

Accordingly, I recommended and the Commission approved implementation of a revised inspection program that will assign resident inspectors at most nuclear plant sites and at selected, critical fuel facilities (Chart 6). By assigning resident inspectors to these sites, the amount of time they spend at the plant will increase significantly. This increased time will provide greater opportunity to observe and measure licensee activities, verify licensee compliance, deter safety-related problems, and respond to significant events. Furthermore, because each resident inspector will be assigned to only one site and will, therefore, have improved knowledge of that plant, inspectors should be able to provide better technical judgments concerning that plant and improve the efficiency of inspections.

In short, these revisions to the program will:

1. Increase NRC knowledge of the conditions at a licensed facility

and provide a better technical base for regulatory action.

2. Lessen the program's reliance on the accuracy and completeness of licensee records by improving the inspector's ability to independently verify licensee performance.

3. Provide additional assurance that licensee management-control systems are effective and that licensee performance is acceptable.

Also, as part of the revised program, we will increase emphasis on the analysis of licensee and inspection program performance from a national perspective, and we will build in mechanisms to insure that we maintain inspection program uniformity and inspector objectivity.

This revised inspection program affords a balanced examination of licensee activities that contribute to safety, safeguards and environmental protection. The resident inspectors will be similar to the generalists (or principal inspectors) in the current program and they will conduct general inspections over a broad area ranging from activities of the reactor operators to the health physics and physical security programs. However, highly detailed inspections will be conducted by specialists who will continue to be assigned in the regional offices. Performance appraisal will involve assessment teams that make indepth measurements of various aspects of reactor construction and operation. The teams will analyze inspection and licensee reports to identify potential weak spots and correct developing problems before they present

threat to the public. The performance appraisal teams will also ndependently evaluate the effectiveness of the inspection program including the effectiveness and objectivity of the resident inspectors). 'eriodic critical reviews of selected areas of licensees' activity ill provide insight into the performance of the regional inspection Program and the resident inspectors.

As the new program develops, resident, regional and performance praisal inspectors will perform an increasing number of independent nfirmatory tests and measurements at the licensee's site. While NRC is performed some radiological measurements since the early 1970's, an Icrease in other areas, such as nondestructive examination (radiography, trasonic testing, etc.) and instrument calibration is included in the evised program. The purpose of these measurements will be to gain eater confidence that the licensee's quality-assurance system is perorming properly. That is, the licensee will remain responsible for accomlishing tests and examinations of all elements of the nuclear plant, but RC will increase its number of independent tests in order to be sure that he licensee is performing properly.

Moreover, there is more information to be gained about the effectiveless of management controls through observation of an operation or a test in progress than by solely examining records of operations and tests. Thus, resident inspectors will be particularly valuable in increasing observation of preoperational tests, power ascension tests, surveillance tests, routine maintenance and operations.