ML16341E364

Notifies That Facility SALP Review Board Established.Board Will Convene on 870909.Projected Date for Meeting W/Util,If Necessary,Scheduled for 871014.Performance Analysis for Assigned Functional Areas Requested by 870825.W/stated Info

ML16341E364
Person / Time
Site:	Diablo Canyon
Issue date:	07/28/1987
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Chaffee A, Mendonca M, Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8708030077
Download: ML16341E364 (40)

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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION V 1450 MARIALANE,SUITE 210 WALNUTCREEK, CALIFORNIA94596 JUL 28 l987 Docket Nos. 50-275/50-323 Report Nos. 87-29/29 MEMORANDUM FOR:

FROM:

References:

A. Chaffee, RV R. ZiIIIIerman, RV M. Hendonca, RV P. Narbut, RV C. Tramell, NRR G. Knighton, NRR S. Richards, RV J. Elin, RV J. Burdoin, RV H. Padovan, RV K. Johnston, RV C. Hooker, RV D. Schaefer, RV K. Prendergast, RV D. F. Kirsch, Deputy Director Division of Reactor Safety and Projects, RY SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

FOR DIABLO CANYON NUCLEAR POWER PLANT UNITS 1 AND 2- (AUGUST.

1, 1986 THROUGH JULY 31, 1987)

(1)

NRC Manual Chapter

0516, SALP Program, dated July 25, 1986 (2)

Region V Instruction 0701 Pursuant to references (1) and (2) above, a Diablo Canyon SALP Review Board is established.

Based on current assignments, the Board consists of the addressees listed above and myself who will serve as the chairperson.

John Burdoin will serve as the Board Secretary.

The Board will convene at 8:30 a.m.

on September 9, 1987, at the Region V office.

The projected date for a SALP meeting with the licensee (if deemed appropriate) is tentatively scheduled for October 14, 1987 (this has not been discussed with the licensee).

ItIembers of the Diablo Canyon SALP Board are herewith provided a

SALP guidance package to be used in preparing performance analyses of the various functional areas.

This package consists of the following:

Description of the functional areas (Attachment 1)

Evaluation criteria (Attachment 2)

Attributes for the evaluation criteria (Attachment 3) 8708030077 8?0728 PDR.

ADQCK 05000275 G

Performance categories (Attachment 4)

SALP evaluation matrix (Attachment 5)

Sample functional area performance analysis (Attachment 6)

Consistent with reference (1), the anticipated outline of the SALP Report is shown below, along with the individual(s) assigned lead responsibility for preparing each section.

I.

Introduction Burdoin Data on inspection effort, enforcement history, and licensee event reports wil,l be distributed to the Board members by John Burdoin in the near future.

II. Criteria III. Sugary of Results IV.

Performance Analyses A.

Plant Operations B.

Radiological Controls C.-

Maintenance D.

Surveillance E.

Fire Protection F.

Emergency Preparedness G.

Security-H.

Outages I.

guality Programs and Administrative Controls Affecting Safety J.

Licensing Activities K.

Training and gualification Effectiveness V.

Supporting Data and Summaries Burdoin Burdoin Narbut Hooker Narbut Narbut Richards Prendergast

Schaefer, Narbut Al1*

Traranell**

Narbut/Elin*

Burdoin Provide written input addressing observations during the SALP period.

The Board secretary will consolidate these into one section.

Provide NRR inputs on other functional areas directly to the responsible individual as soon as possible.

Each person assigned lead responsibility for a functional area sha11 prepare a

performance analysis and submit it to John Burdoin by August 25, 1987.

Each performance analysis-shall be prepared as follows:

Assess the licensee's performance in the functional area based upon inspections performed, available data, and observations of licensee performance during the SALP period.

Obtain inputs from others who had inspection responsibilities in the functional area.

In assessing the licensee's performance, use the guidance in Attachments l through 4..

2.

Prepare the licensee's performance analysis for the functional area following the format of Attachment 6. If appropriate, discuss the trend of the licensee's performance since the previous SALP period (refer to ).

The analysis should reference pertinent data, enforcement items, or events when appropriate, but should be rinci all a

ualitative anal sis of the licensee's performance 1n t e area depending upon eve of activity, approximately one-half page to a page and a half in length when single-space typed).

3.

Include recommendations for licensee actions related to the functional area.

4.

Provide a copy of the SALP evaluation matrix (Attachment 5), assigning a

performance category for each evaluation criterion.

5.

Separately.,

identify appropriate recommendations for NRC actions (e.g.,

increase or reduce inspection. resources).

These recommendations will not be included in the SALP report, but will be a part of the Board Chairman's memorandum which transmits the report to the Regional Administrator.

For RITS reporting purposes, time expended for this Diablo Canyon SALP effort should be charged to Report Nos. 50-275/87-29 and 50-323/87-29.

By copy of this memorandum, the Director, Office of Investigations, San Francisco Field Office is requested to provide (by August 25, 1987) a sugary of major investigative activities involving Diablo Canyon and their results.

In addition, by copy of this memorandum, the offices of NMSS and AEOD are requested to provide performance analysis information by August 25, 1987.

Orang'in0l:lgnc'cf 6"y,'.

P, fir-".ch ~.

D. F. Kirsch, Director Division of Reactor Safety and

Projects, RV CC:

J. Partlow, NRR H. Thompson, NMSS E. Jordan, AEOD P. Polk, NRR R. Marsh, OISFFO F. Wenslawski, RV M. Schuster, RV J. Martin, RV G. Yuhas, RV J. Montgomery, RV R. Scarano, RV R. Fish, RV E. Wenzinger, RI bcc:

G.

Cook B. Faulkenberry docket file M. Smith Project Inspector Resident Inspector RSB/Document Control Desk (RIDS) (IE40)

REGION V

JBurdoin/dot HMendonca 7/~'f87 Py 7/~7 RZimmerman DKir ch 7/a+87 7/g, /87 U ST COPY RE VEST COPY REQUEST CQPY REQUEST PY YES NO S /

NO YES CV YES 0

0 PDR YES /

NO

ATTACHMENT 1

042 Functional Areas.

A grouping of similar activities, Oper atina Phase actors Plant 0 erations Consists chiefly of the activities of the licensee's operational staff (e.g.,

licensed operators, shift technical

advisors, and auxiliary operators).

lt is intended to be limited to operating activities such as:

plant

startup, power operation, plant

shutdown, and system lineups.

Thus, it includes activities such as reading and logging plant conditions; respondina to off no( mal conditions; manipulating the reactor and auxiliary controls; plant-wide housekeeping; and.

control room professionalism..

2.

Radiolo ical Controls includes the following areas of activity which may be evaluated as separate subareas to arrive at a

consensus rating for this functional area.

(a)

Occupational Radiation Safety - includes controls by li-censees and contractors for occupational radiation pro-

tection, radioactive materials and contamination

controls, radiological surveys and monitoring, and ALARA programs.

(b)

Radioactive Naste Management - includes processing and on-site storage of gaseous, liquid and solid wastes.

(c)

Radiological Effluent Control and Monitoring -

includes gaseous and liquid effluent controls and monitoring, offsite dose calculations and dose limits, radiological envijonmental monitoring, and the results of NRC's confirmatory measurements program.

(d)

Transportation of Radioactive Materials - includes procure-ment and selection of packages, preparation for shipment, selection and control of shippers delivery to carrier s, receipt/acceptance of shipments by receiving

facility, periodic maintenance of packagings

and, for shipment of

. spent fuel, point of origin safeguards activities.

(e)

Mater Chemistry Controls - includes. primary and secondary systems affecting plant water chemistry water chemistry control program and program implementation, chemistry facilities, equipment and procedures, and chemical analysis quality assurance.

3.

Maintenance 4'ncludes all licensee and contractor activities associated with preventive or corrective maintenance of instrumentation and control equipment and mechanical and electrical systems.

Surveillance includes all sur veillance testing activities as well as alt inservice inspection and testing activities.

Examples of ac ivities included are:

instrument calibrations, equipment operability

tests, containment leak rate

tests, special

tests, inservice inspection and performance tests of pumps and valves, and all other inservice inspection activities.

ATTACHMENT 1 4

~

~

Fire Prot tion r

h Includes routine housekeeping

. (combustibles, etc. )

and fire protectionlprevention program activities.

Thus, it includes the storage of combustible material; fire brigade staffing and training; fire suppression system maintenance and operation,"

and those fire protection features provided for structures,

systems, and components important to safe shutdown.

Emeroenc Preparedness includes activities relating to the implementation of the emer-gency plan and implementing procedures, Thus, it includes such activities as licensee's performance during exercises which test the

licensee, state, and local emergency plans; plan administration and implementation; notification; communicationsI facilities and equipment; staffing; training; assessment; emergency classification;

.medical treatment:;

radiological expo-sure control; recovery; protective actions; and interfaces with onsite and offsite emergency response organizations.

~Seeurit Includes all activities whose purpose is to ensure the security of the plant.

Specifically it includes all aspects of the licensee's security program (e.g.,

access

control, security

checks, safeguards).

Outaaes Includes all licensee and contractor activities associated with major outages.

Thus, it includes refueling, outage management, major plant modifications, repair s or restoration to major components (e.g.,

steam generator tub5 repairs or primary loop piping replacement),

and all post-outage startup testing of systems prior to return to service.

4 ualit Pro rams and Administrative Controls Affectin ualit

~ ~ ~ ~

Includes all management

control, verification and oversight activities which affect or assure the quality of plant activities, structures,

systems, and components.

This area may be viewed as a comprehensive management system for controlling the quality of work performed as well as the quality of verification activities that confirm that the work was performed correctly.

The evaluation of the effectiveness of the quality assurance system should be based on the results of management actions to ensure that necessary

people, procedures, facilities, and materials are provided and used during the operation of the nuclear power plant.

Principal emphasis should be given to evaluating the effectiveness and involvement of management in establishing and assuring the effective implementation of the quality assurance program along with evaluating the history of ATTACHMENT 1 PAGE 2

~ ~

si

li ee performance in the key a

s of.

committee activities, de n

and procurement

control, control of design change processes, inspections,

audits, corrective action

systems, and records.

/

10.

I icensino Activities Includes all activities supporting the NRC review of amendment

requests, exemption

requests, relief

reports, response to generic letters and bulletins, and TMI items classified as:

Multi-Plant

Actions, Plant Specific

Actions, and TMI (NUREG"0737) Actions.

In addition, it includes an assessment of licensee activities related to design and safety issues.

It also includes NRC meetings that dealt with significant licensing issues.

ll.

Trainin and uglification Effectiveness Although this functional area is limited to the

'following categories of facility training/retraining so as to parallel those training programs covered by the Commission Policy Statement on Training and Qualification, this functional area includes all activities relating to the effectiveness of the training/retraining and qualifications progiam conducted by the licensee's staff and contractors for these categories of facility training.

ther categories of facility training/retraining should be treated as evaluation criteria for the other functional areas.

'J'a}

Non-licensed operators

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(b} Control room operators-e(c)

Senior control room operators/shift supervisors (d} Shift technical advisors

'e)

Instrument and control technicians (f)

Electrical maintenance personnel

.(g)

Mechanical maintenance personnel (h)

Radiological protection technicians (i)

Chemistry technicians

~

~

(j)

Onsite technical staff and managers ATTACHMENT 1 PAGE 3

ATTACHMENT 2

Q45 Evaluation Criteria.

Elements which must be assessing a licensee's performance in a functional area.

I a.

The evaluation criteria are as follows:

Management involvement in assuring quality considered when 2.

Approach to the resolution of technical issues from a safet standpoint saey 3.

Responsiveness to NRC initiatives 4.

Enforcement history Operational and Construction events (including response to, analysis of, and corrective actions for)

Staffing (including management) b.

Guidance for using these critei ia to arrive at a

category assignment is found in the appendix to this chapter.

ATTACHMENT 2

ATTACHMENT 3

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TABLE 1 EVALOATIOH CRITERIA WITH ATTRIBllTES FOR ASSESSMEHT OF LICENSEE PERFORHAHCE Cateaora 1

~Cate o

2 1.

)fana ement Invo)vement ln Assurin ualit

~cate o

consistent evidence of prfor planning and assignment of priorit$es; we)) stated, control)ed and explicit

'rocedures for control of activities

. we)) stated, disseminated, and understandable po)icies, decfsionmaking consistently.

at a level that ensures adequate management review and a

evfdence of prior planning assignment of priorities;

stated, defined procedures for contro) of activities I

adequately stated and understobd policies I

decisionmaking usually at a level that ensures adequate management review

)fttle ev$ dence of prior planning and assignment of prfotities; poor)y stated or

$ 11 understood procedures for control of activities poorly stated, paarly under-stood or nonexistent policies decisionmaking seldom at a level that ensures adequate management review corporate management fre-quent)y involved in site actfv$ ties corporate management usually fnvo)ved in site activities reviews generally timely,

thorough, and technically sound records generally complete, we) I maintained, and available reviews timely, thorough ard technica)ly sound e

C records comp)ete, we))

maintained, and available corrective action fs usually taken but may not be effective

,.at correcting the root cause of of the problem, as indicated by occasional repetition procedures and policies rarely procedures and pol fcies violated strictly adhered to corrective action is effective, as indicated by lack of repetftion corporate ma'nagement seldom fpvo)ved in site activities e

reviews not time)y, thorough or technically sound records not complete, not ue) maintained, or unavailable procedures and policies occasionally violated corrective actfon fs not time or effective and generally ad dresses symptoms rather than root causes, events are reoetitfve 2.

A roach to the Reso)utfan of Technfca)

Issues fram a Safet Stand oint

~ e c)ear understanding of issues demonstrated conservatism routinely exhibited ~hen potential for safety significance exists techn$ cal)y sound and thorough approaches in almost all cases

'imely r esolutions fn almost a)l cases understanding of issues generally apparent conservatism generally exhibited viable and generally sound and thorough approaches generally timely reso)utfons understanding of issues frequently lacking meets minimum requirements often vfable approaches; but

'lacking fn thoroughness or depth l

reso)utians often delayed 3.

Res onsfveness to HRC Inftfatives meets deadlines tfmely reso)utfan of fssues technical)y sound and thorough responses in almost all cases acceptable resolutions proposed fnitial)y in most cases genera) ly tfmely responses few longstanding regulatory issues attributable to licensee vfable and generally sound and thorough responses acceptable resolutions generally proposed frequently requires extensions of tfme longstanding regu)atary issues attributable to licensee often vfable responses, but lacking in thoroughness or depth considerable HRC effort or repeated submittals needed to obtain acceptable resolutfans ATTACHMENT 3 PAGE 1

~Cate e

I TAStE 1 (continued)

~Cate e

2

~Cate e

t 4.

Enforcement Hfstor major violations are rare and are not indicative of programmatic breakdown mfnor violations are not repetitfve and not indicative of programnatfc breakdown corrective action is prompt and

. effective major violations are rare and may indicate minor programmatic breakdown multiple minor violations or minor programmatic breakdown indicated we*

corrective action is timely and effective fn most cases multiple major violations or programmatic breakdown indicated minor violations are repetitive and indicative of programmatic breakdown corrective action is delayed or not effective S.

0 erational and Construction Events few significant operatfonal or construction events, attribut-able to causes under the licensee's control, have occurred that are relevant to this functional area events are promptly and completely reported events are properly identi-fied and analyzed 1

6.

Stafffn Includfn Hang enent posftfons are identified, authorities and responsibil-ities are we)l defined vacant key positions are filled on a priority basfs expertise fs available within the staff; rarely needs out-side consultants; staffing fs ample as fndicated by control over backlog and overtime experience levels for manage-ment'and operatfons personnel exceed commitments made by 1icensee at time of licensfng occasional significant operational or construction events, attribut-able to causes under the licensee's control, have occurred that are relevant to this functional area events are reported in a timely

manner, some information may be lacking events are accurately identffied, some analyses are marginal key positions are fdentiffed, and responsibilities are defined key positions usually fflied fn a reasonable tfne expertise fs usually available within the staff; makes appropriate use o( consultants; staffing is

adequate, occasional difficulties with backlog or overtime experience levels for management and operatfons personnel meet commitments made by licensee at time of licensing frequent significant operational or construction events, attribut-able to causes under the licen-see's control, have occurred that are relevant to this functional area event reporting fs frequently late or incomplete events are poor'ly identified or analyses are marginal.

events are associated with programma-tic weaknesses positions are poorly identified,'r authorities and responsibil-ities are fll defined key positions are left vacant for extended periods of time very little expertise within th staff; excessive reliance on consultants; staffing is weak o minimal as indicated by excessi backlog or overtime experience levels for managemen and operations personnel are be.

low cocctmf tnents made by licenset at tine of licensing ATTACHMENT 3 PAGE 2

ATTACHMENT 4

S 043 Performance Categories.

A rating of licensee performance & a given functional area.

b; Reduced NRC attention may be appropriate.

Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a

high level of performance with r espect to operational safety and construction quality is being achieved.

2 NRC attention should be maintained at normal levels.

Licensee management attention and involvement are evident and are concerned with nuclear safety.

Licensee resources are adequate and reasonably effective so that satisfactory performance with respect to opera-tional safety and construction quality is being achieved.

Both 'RC and licensee attention should be increased.

Licensee management attention or involvement is acceptable and considers nuclear

safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance'ith r espect to operational safety and construction quality is being achieved.

I 044 Trend.

The SALP Board may determine to include an appraisal of the'erformance trend of a functional area No.rmally, this performance trend should only be used where both a definite trend of performance is discernible to the Board and the Board believes that continuation of the'rend may result in a change of performance level.

The Board's appraisal of the performance trend, if used,- should appear as a Board Comment.

It should be used selec-tively and should be reserved for those instances where the Board believes that it is necessary to focus NRC and licensee attention on an area be-cause of a

declining performance

trend, or to credit licensee performance because of an improving.trend.

The trend, if used, is defined as:

a.

~lmnrovin Licensee performance was determined to be improving near the close of the assessment period.

b.

~ectininc}

Licensee per formance was determined to be declining near the close of the assessment period.

ATTACHMENT 4

ATTACHMENT 5

EVALUATION MATRIX FOR OPERATING PHASE FUNCTIONAL AREAS CJE CJ OrAl C

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CJ oyw E

S-CJOl th AS th C+

AS O

AS

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r S

O4 th CJ th Cx'. Cl ~O Cl Vl C4 th ClC AS Or

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AS ~

CJ 0 Vtt S

CJ C7 I VS D

th Cl 0'S 1f th Cl CJ Vl O

CL th Cl O

th

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AS AS O Ih W C AS CJ l

CJ UJ Ct C)

CJE CJOl ASC Ol

'Cl Plant Operations Radiological Controls Maintenance Surveillance Fire Protection Emergency Preparedness Security Outages guality Programs and Administrative Controls Affecting guality Licensing Activities Training and gualification Effectiveness ATTACHMENT 5

ATTACHMENT 6

PERFORMANCE ANALYSIS A.

fFunctional Area being discussed]

'I.

I

~Anal ala

[The analysis of "the licensee's performance in an area should include pertinent facts and observations to highlight the specific strong and weak aspects of the licensee's performance.

These facts and observations shall be presented in a manner to place matters in perspective and to allow the reader to understand the rationale for stated conclusions.

This analysis should concentrate on the adequacy of the licensee's management control

systems, adequacy of r esources, training of per sonnel, etc.,

and the effectiveness of these efforts.

Upon presentation of the

analyses, the attributes associated with the specified criteria are to be referred to for purposes of both completeness and to compare the conclusions reached with the attributes of each category.

The attributes listed in Part II are specifically oriented toward this and should be utilized.

In no event,

however, are the examples of licensee performance for specific attributes to be used as stand-alone assessments; they represent a sampling of possible conclusions which must be supported by appropriate

facts, observations or analysis.'ach analysis should be written to avoid either 10 CFR 2.790 or safeguards information.

The analysis section is composed of three major subsections:

A brief account of the inspection activity which occurred in this area.

2.

A brief summary of the previous evaluation if there has been a

significant change or if there should have been significant improvement but there was not.

A summary of the strengths, weaknesses, and other significant observations made by the NRC. staff during the evaluation period.

Conclusion

[Provide the per formance assessment (Category 1,

2, or 3) for each functional area considered. j 3.

Board. Recommendations fInclude any general or specific Board recommendations per-taining to either licensee management attention or NRC inspection activities in a

functional area.

If appropriate, include a

trend assessment (improving or declining),

characterizing licensee per formance near the close of the assessment period.

Note that even in the absence of' recommendation to vary inspection

levels, the Regional Office may do so based on the assessment as discussed in appropriate chapters of the lf manual.]

ATTACHMENT 6 PAGE 1

~ P 0,

.0 SAMPLE SALP PEPZORMANCE ANALYSIS Surveillance O~

.The surveillance program was inspected on a monthly. basis by the resident inspectors and periodically by the regional staff throughout this SALP period.

During thxs SALP period the licensee instituted a comprehensive surveillance program which is maturing under constant management and staff attention.

During the earlier part of the period the licensee

, and received, changes or schedule relief for some Technical Specification required surveillances.

These were short notice, xn some cases involving after-hours telephone requests which might have been avoided through stronger roblems management control, internal communications and planning S

h p

ems were not experienced in the latter part of the period.

One violation in the surveillance area was id t f d

d' en i xe regar xng the a

a >on of gumpers and the independent verification thereof.

The NRC considers 14 licensee event reports (LERs) to be attributed to personnel errors during the many surveillance activities this SALP period.

tfanagement demonstrated no reluctance to properly report and analyze discrepancies.

There were five LERs attributed o

eficiencies in surveillance procedures; management and staff gave much attention to this area and routinely issued changes to improve the accuracy and clarity of procedures.

The licensee instituted a computer matrix of surveillance requirements corresponding

'to Technical Specificati.onrequirements, which appears to have been comprehensive with a few exceptions reported in licensee event reports.

"These were corrected promptly,

and the matrix is routinely updated.

Computer schedules and monitoring h'ave allowed management visibilityof trends in overdue

dates, contributing to avoidance of technical specification violations.

A program of procedure changes was implemented late in the period to fully incorporate independent verification requirements into surveillance procedures, in response to NRC initiatives Conclusion Performance assessment - Category l.

An improving trend in perfonnance was observed during the SALP.

Board Recommendation Continue efforts to correct procedure deficiencies and provide training to the staff in their proper use.,

..hTTACHMEHT 6 PAGE 2

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