ML20032C375

NRC Licensee Assessments

ML20032C375
Person / Time
Issue date:	08/31/1981
From:	Eisenhut D, Michelson C, Moseley N, Sniezek J NRC - SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REVIEW
To:
References
NUREG-0834, NUREG-834, NUDOCS 8111100027
Download: ML20032C375 (68)

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COMMISSION STATEMENT ~

The Commission endorses the staff's factual findings in this report concerning individua; licensee operations. The Commission also encourages licensees to make improvements in the areas of weakness identified by the staff. However, in view of the long time span during which individual plant evaluations were made, the Commission

- does not believe that the relative rankings necessarily represent current conditions.. The Commission has prepared guidance for the ttaff tr 330vern 2ho conduct of future assessments..

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UNITED STATES f.-

4 NUCLEAR REGULATORY COMMISSION 3

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WASHINGTON. D. C. 20555

>e The following was provided as guidance by the Commission in a memorandum, dated October 20, 1981, for W. Dircks, Executive Director for Operations, from S. Chiik, Secretary.

COMMISSION GUIDANCE FOR FUTURE CONDUCT OF THE LICENSEE ATsESSMENT PROCESS On September 22, 1981, the Commission was briefed on the results of the staff's evaluation of licensee performance conducted under the program entitled Systematic Assessment of Licensee Performance (SALP).

The Commission also was briefed on the objectives underlying the program.

The Commission believes. that those elements of the program directed toward fulfil' ting the objectives--especially the objective of improving allocation of inspection resources--should continue in the future.

However, other aspects of the program should be changed along the lines of modifications suggested below:

While it is understandable that the first assessment of licensee performance reached back to two years ago, the timeliness must improve.

The staff should set as a target that assessments for each operating and construction facility will be completed annually. The individual facility issessments should take place at a uniform rate throughout the year.

The assessmer.cs should be made at a regional level.

Involvement of NRC offices other than the Office of Inspection and Enforcement should continue as part of the assessments.

The headquarters activity should be redirected to evaluating the policy, criteria, and methodology for these assessments.

Assessment criteria should be established that do not depend on looking at all plants to determine relative performance (e.g., an average and levels around that average).

The staff should be sure that the new assessment criteria are widely published and well understood. We and the licensees must know what it takes to fall unoer the criteria and rise out from under them.

Also, those doing the assessments should have recognized expertise in applying the criteria.

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'.* staff should ensure the existence of a process for taking licensee responses into account.

Specifically, a licensee must have the opportunity to comment on assessment results before they are made final and the licensee is characterized, e.g., as needing to improve performance.

The adverse implications of ranking utilities can be avoided by adopting three categories for the assessment.

The first category should identify those facilities for which more licensee and hence more NRC attention is needed.

The second category should identify those facilities for which proper balance of licensee and NRC attention has been achieved.

The last category should identify those facilities for which more than adequate attention by the licensee is apparent and hence a reduction in NRC resources for those facilities can Se realized.

Actions identified as needed are expected to be initiated immediately following completion of the appraisal for a particular licensee.

Where these actions include changes in the amount of NRC inspection resources devoted to a facility, criteria should be established to govern such changes (e.g., how many and what type of inspections should be added or subtracted).

The Commission understands that a draft Manual Chapter is currently in use for t.he program.

This Manual Chapter should be rewritten to reflect this Commision guidance.

Within the next month the revised Manual Chapter should be issued by the EDO.

In the meantime, the licensee assessments that are underway should continue with the old guidance until the new Manual Chapter is issued.

New assessments should be started under the new guidance as soon as possible.

Without holding up issuance of the new Manual Chapter, but within the near future, the public should be given an opportunity to evalue.te and comment on the asses ment process that will ultimately be used.

In addition, as future NRC assessment techniques are developed, the staff should devise ways to w wk with the Institute for Nuclear Power Operations (INP0).

By doing so, NRC could gain confidence in our own techniques and perhaps make use of NRC resources more efficiently.

Cont.orning the current summary report prepared by the staff, the Commission authorizes release of the report subject to the following conditions:

this Comminion guidance is displayed prominently on top of the icport.

the statement below is printed boldly on the cover of the report.

COMMISSION STATEMENT The Commission endorses the staff's factual findings in this report concerning individual licensee operations.

The Commission also encourages licensees to make improvements in the areas of weakness identified by the staff.

However, in view of the long time span during which individual plant evaluations were made, the Commission does not believe that the relative rankings necessarily represent current conditions.

The Commission has prepared guidance for the staff to govern the conduct of future assessments.

NUREG-0834 Final Report NRC Licensee Assessments Manuscript Completed: August 1981 Due Published: August 1981 Systematic Assessment of Licensee Performance Review Group (SALP)

U.S. Nuclear Regulatory Commission Wahington, D.C. 20l45 el......

COMMISSION STATEMENT The Commissior. endorses the stati 3 ! actual findings in this report concerrJng individual heensee operatons. The Commission alw encourages beensees to make improvements in the areas of weakness identified by the staff. However, in view of the long time spa;.

during which individual plant evaluations were made, the Commission does not beheve that the relative rankings necessanty represent cuerent conditons. The Commission has prepared guidance for the staff to govern the conduct of future essessments.

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FOREWORD l

This report provides facility ratings for operating power reactor licensees and construction permit holders as determined by the Systematic Assessment of Licens'ee Performance'(SALP) Review Group.

Facilities have been rated as above l

average, average, or below average.

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Because-the SALP process involves collection of data over an appraisal period of at least one year, followed by an evaluation interval, much of the perform-ance information from which this review was made is from one to one and a half years old. Weaknesse's found during the appraisal period'are in various stages of correction by the licensees.

This report does not reflect such corrective actions since they are-dynamic and do not lend themselves to inclusion as a l

specific interim appraisal update.

The effect of corrective actions will be l

reflected in the next SALP review.

This appraisal delay is an inherent feature of SALP.

Details concerning licensee corrective actions are available in inspectior. reports and correspondence in individual facility docket files.

l Any rating process that uses judgmental elements is susceptible to challenge.

The facility ratings in this report are no exception.

It is expected that sorae will feel that certain elements of performance were not given adequate emphasis and that others were overempha' sized.

Nevertheless, the facility I-ratings represent the best collective judgment of senior NRC managers viewing licensee nuclear-safety performance from a national perspective.

A rating of below' average does not mean that a facility was unsafe or that its operation

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or-construction should be stopped.

The expected performance level for nuclear l

. facilities is high, as it should be.

A rating of below average means that the facility was not meeting the full measure of these high expectations and that, relative to the population of nuclear facilities, the facility's performance was judged to be less desirable than n.ost other facilities.

The overrid!ng goal of SALP is improved performance of the industry as a whole and greater assurance to the public that nuclear power reactors are buO t and

-operated. safely.

Areas of weakness were identified at various facilities i

during the'SALP.

These weaknesses were discussed with the respective licensee management organizations and improvements in these areas are expected from licensee corrective actions already taken or initiated.

The regulatory process has not historically made an effort to highlight good performance.

Imperfec-

.tions or perceived weaknesses are emphasized and reported more than positive attributes.

The NRC has focused, and continues to focus, its attention on licensees warranting increased regulatory effort to ensure that their per-formance is adequate.

The appraisal of licensee performance is a task from the "NRC Action Plan Developed as a Result of the TMI-2 Accident" (NUREG-0660).

The intent of the appraisal and rating process is not to " label" licensees, developing a sense

'of complacency for those rated above average or a sense of condemnation for those rated below average.

The intent is for the findings of the Review Group be used for attaining a high level of performance by all licensees.

5 LP REVIEW GROUP e

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'{C-Jr es H. Sniezek, Director DiNJision of Resident and tegional Reactor Inspection, IE NA Norman C. Moseley, Director, Division of Program Development and Appraisal. IE, Review Group Chairman Report on Licensee Assessntents prepared for the SALP Review Group by R. H. Wessman, IE 11

ABSTRACT This is the first report concerning NRC's program entitled Systematic Assessment of Licensee Performance (SALP).

It provides facility ratings for operating power reactor licensees and construction permit holders as determined by the NRC's SALP Review Group.

Facilities are rated as above average, average or below average.

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CONTENTS Page F0RWARD...............................................................

i ABSTRACT..............................................................

iii 1.0 INTR 000CTION.............................

1 2.0 THE SALP EVALUATION PR0 CESS......................................

3 3.0 SALP REVIEW GROUP FUNCTIONS......................................

5 4.0 SALP REVIEW GROUP FACILITY RATINGS...............................

6 4.1 Ratings for Operating Power Reactor Facili ties..............

7 4.2 Ratings for Power Reactor Facilities Under Construction.....

7 APPENDIX A - PERFORMANCE ELEMENT SUMMARIES FOR OPERATING POWER........

A-1 REACTOR FACILITIES RATED AB0VE AVERAGE OR BELOW AVERAGE Part 1 - Above Average Operating Power Reactor Facilities........

A-1 Part 2 - Below Average Operating Power Reactor Facilities.........

A-5 APPENDIX B - PERFORMANCE ELEMENT SUMMARIES FOR POWER REACTOR..........

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FACILITIES UNDER CONSTRUCTION RATED BELOW AVERAGE ATTACHMENT 1 - COMMISSION INFORMATION PAPER ON " SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE," SELY-80-83, DATED FEBRUARY 12, 1980.

AETACHMENT 2 - SALP REVIEW GROUP CHARTER v

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NRC LICENSEE ASSESSMENTS

1. 0' INTRODUCTION A licensee appraisal program has been implemented in accordance with Task I.B.2 of NUREG-0660, Volume 1, "NRC Action Plan Developed as a Result of the TMI-2 Accident." The program itself is described in SECY 80-83 dated February 12, 1980 and the SALP Review Group Charter approved by the Executive Director for Operations on August 25, 1980.

Copies of these documents are attached.

This first report presents the findings of the SALP Review Group based on a review of the licensee performance records. Among the records reviewed were the licensee avaluations made by NRC Regional Offices for operating power reactor facilities and power reactor facilities under construction.

In this

.-t, an operating power reactor facility or a power reactor facility under construction is referred to interchangeably as the " facility," the " licensee facility," or the " licensee." The evaluation period for an individual facility varied from twelve to eighteen months and generally fell between January 1,1979 and December 31, 1980.

The regional licensee performance evaluations, in conjunction with other information, provide the SALP Review Group with a systematic basis for deter-minir:g the relative performance of licensees.

The objectives of the SALP program are to:

Improve licensee performance.

Improve the NRC regulatory program.

Identify other-than-average licensee performance.

Provide a basis for management allocation of NRC resources.

Facility ratings of above average, average, or below average were assigned by the SALP Review Group using the gufdance provided below.

Not all the indicated attributes were necessarily present for a particular rating to apply.

The ratings used and their charactpristics are as follows:

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L 1.

Above Average--A combination of characteristics having positive or desir-able qualities

• displaying unusually good performance.

A facility is characterized as being above average if there is little evidence of administrative, managerial, or material problems; if there are a relatively low number of substantive construction or operational events or. items of noncompliance (when compared to others); and if there are few (or no) substantial regulatory issues involving the facility.

There are few (if any) significant items of noncompliance, no significant breakdown in management controls, and a subsu ntial fraction of the significant activity areas reviewed are characterized as above average.

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' Average--A combination of characteristics having typical or represent-l ative qualities; displaying usual performance.

An average facility may or may not display evidence of administrative, managerial or material problems, substantive construction or operational events, significant items of noncompliance, or regulatory issues.

If

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such evidence does exist, the problem areas are such that they detract L

little from the licensee's ability to meet nuclear safety requirements and they exist in only a few of the activity areas.

The facility's i

performance is similar to the performance of a majority of facilities, and a substantial fraction of the significant activity areas reviewed are characterized as average.

l 3.

Below Average--A combination of characteristics having negative or undesir-able qualities; displaying less than desirable performance.

A facility is characterized as being below average if there exists evidence =

of significant-administrative, managerial, or material problems in several activity areas; substantive construction or operational events (when compared to others); significant items of noncompliance (when compared to others); evidence of repeated items of noncompliance; or several regulatory issues and mongement contacts involving the licenste's performance.

The licenses may'have had difficulty in its ability to meet requirements important to nuclear safety. A substantial f raction of the significant activity areas reviewed may be characterized as below average.

. A finding of below average does not imply that a facility must be shut down or that construction of a facility must'be interrupted.

These ratings are only

relative, Simply stated, a below average facility displays negative char-acteristics or undesirable qualities that we not typical of a majority of f at.ili ties.

The SALP program is an evolving program and this is the first report providing facility performance ratings.

The Review Group found that, as with any new program, changes are necessary to correct programmatic weaknesses.

Regional SALP Board evaluations were not all conducted in an identical fashion.

Regional SALP Board reports varied in scope and depth.

Alt.o, the evaluation process itself involved elements of subjectivity.

Steps have been taken to clarify definitions and revise instructions governing the SALP process to provide a more consistent approach in the future.

2.0 THE SALP EVALUATION PROCESS This section describes the basic structure and methodology used by the NRL to systematically assess (acility performance.

This assessment program was applied to power reactor fatilities with an operating license and power reactor facilities under construction.

Because the SALP process is a licensee management assessment process, plants with amitiple units were evaluated as a single facility (unless the individual units at the same location were under different management organizations).

Construction and operating plant eval-uations were separated.

A licensee with several facilities received a separate rating for each facility.

An evaluation of each licensee's performance was made by a Regional SALP Board consisting of individuals who were involved in the inspection and licensing activities of the licensee such as inspectors, regional managers, and NRR project managers.

The Regional SALP Board reviewed licensee technical and manage:nent performance and the quality of licensee safety actions.

The Regional SALP Board discussed areas of licensee activity judged as war-ranting additional or reduced actions. Additional action included meetings

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4-t with. licensee management, inspection program increases, recommendations.to'the licensee,-or recommendations for NRC action.

Reduced actions were generally a

-reduction in the prescribed inspection programi l

L Since the Regional SALP Board review was based on historical perspective, l

there was' evidence of NRC action already taken to improve the licensee's-L

. performance in an activity area where the finding was below average.

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finding of less acceptable performance than below average (i.e., issues were of such'a significant nature'that they warranted concern over the safety of

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l continued operation or construction prior to their correction) did not occur during the SALP evaluation.

Any time that significant issues requiring licensee corrective action were identified, the NRC actea promptly to ensure such action was taken.

Licensee or NRC actions may not have been completed at the time'of a Regional SALP Board meeting, but the commitments or plans of action

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.were established.

Following the Regional SALP Board evaluation, NRC management met with the l

corporate management of each facility that had been evaluated.

This meeting provided a forum for discussion of issues relating to the facility's per--

., fo rmance.

These meetings were chaired by senior regional management.

The meeting discussion topics included the following items:

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Performance evaluation--Summary of the performance evaluations in each I

functional area considered; indications of significant performance -

trends; and capability and responsiveness of licensee personnel.

2s Enforcement history--Number, severity, and repetitive nature of items of noncompliance; adequacy and timeliness of responses to items of noncor-pliance; adequacy of corrective action and generic reviews; and indica-t tions of significant trends.

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Reportable events--Significance and repetitive nature of reportable I

operational events or construction deficiencies; nature of causally l

. linked events; adequacy and timeliness of the reports; adequacy of.

corrective action and generic reviews; adequacy of-the licensee's event response system; and indications of-significant trends and patterns.

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Communications with NRC--Adequacy of bulletin responses and technical.

correspondence with.NRR and other NRC offices.

5.

' Inspection findings--Sta'tus of significant unresolved and open items, and indications of significant trends.

6.

Overall performance conclusion--Conclusion on facility performance.

'At the meeting, the regional manager'also identified those aspects of the licensce's performance that needed improvements based on the NRC assessment.

Other matters were also discussed at the discretion of the regional manager.

A report documenting the NRC meeting with the licensee was sent to the licensee and to the NRC Public Document Room.

.-The. final' step in the SALP process was the national overview and rating provided by the SALP Review Group.

The Regional SALP Board evaluation results were forwarded to.the SALP Review Group.

Four senior NRC managers from NRR, AE00, and IE reviewed the Regional SALP Board evaluations and other records and rated the licensee facilities as above average, average, or below average.

3.0' SALP-REVIEW GROUP FUNCTIONS The. objectives of the SALP Review Group are to (1) identify unacceptable elements of licensee performance by reviewing regional licensee appraisals; (2) improve licensee performance by recommending corrective action to the Director, IE and/or the Director, NRR; and (3) overview the consistent appli-

-cation of the SALP program.

The Review Group's goal is to rate on a yearly basis the performance of each operating power reactor facility or power reactor facility under construction.

The responsibility for the final national ratings of facilities as either

.above average, average, or below average is vested in the SALP Review Group.

The ratings for this first evaluation represent the best collective judgment of the' group and was based on review of the following information:

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The evaluation of licensee performance fur each facility as prepared by the NRC Regional SALP Board, which included the NRR Project Manager for the facility evaluated.

2.

Information gathered by the SALP Review Group staff.

3.

Results of inspect. ions performed by the IE Performance Appraisal Branch and the llealth Physics Appraisal Teams.

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Consideration of the extent and nature of Construction Deficiency or Licensee Event Reports, number and seriousness of items of noncompliance, l-and number and severity of enforcement actions.

4.0 SALP REVIEW GROUP FACILITY RATINGS i

This section provides the facility ratings made by the SALP Review Group.

It is presented in two parts.

The first part provides ratings for operating power reactor f acilities, and the second part provides ratings for power reactor facilities activisly under construction.

For those licensee facilities rated as above average or below average, facility performance elements leading to that rating are summarized.

No summary of performance elements is provided for licensee facilities rated as average.

The performance of an average facility was similar to the performance of a l

majority of the f acilities rated and lacked distinguishing characteristics l

that warranted inclusion of a summary in this report.

Additional information regarding licensee assessments may be found in the public document room as part of'the-IE report documenting the regional management meeting with the licensee.

1here are several reasons why summaries of licensee performance elements differ for different facilities.

First, the SALP Review Group received significant input from the Regional SALP Board evaluation.

The regional reports varied in format, style, and characterizations applied to licensees, since the agency. directives were general in their requirements.

For example, ane region used the term " unsatisfactory" to describe below average per-fo mance. The terms " acceptable" and " adequate" were used interchangeably.

Second, inspection and licen ing activities were not the same for all licensees.

f or example, not all facilities received the health physics appraisal or Per-formance Appraisal Branch inspection during the evaluation period, and the findings of these comprehensive team inspections may influence a facility SALP evaluation.

In addition, the evaluation periods were dt ?ferent for different facilities.

L1 Ratings for Operating Power Reactor Facilities Table 1 provides the ratings for operating power reactor facilities.

The facilities in each rating category are listed alphabetically.

Performance elements for facilities rated as above average or below average are summarized in Appendix A.

Two power reactor facilities with operating licenses were not evaluated.

Three Mile Island 2 was not evaluated because it was shut down for accident recovery pursuant to an NRC Order.

Humboldt Bay was not evaluated because it has been shut down pursuant to an NRC Order since 1976.

4.2 Ratings for Power Reactor Facilities Under Construction Table 2 provides the ratings for power reactor facilities under construc-tion.

The facilities in each rating category are listed alphattetically.

Performance elements for facilities rated as below average are summarized in Appendix B.

The SALP Review Group found it difficult to rate power reactor facilities under construction.

These facilities were at varying stages of activity and completion.

The licensing and inspection activities varied with the level of licensee activity.

In a number of instances very little infor-mation was available.

The SALP Review Group did not find facilities under construction with distinguishing characteristics that would permit categorizing them as above average.

The SALP Review Group evaluated three facilities (Marble Hill., Scuth Texas Project,andWNP-2)whereconstructionwasnotactivel'yinprogrbssduring the full extent of the evaluation period.

Two of these facilities received

_._ a Regional SALP Board evaluation.

The preponderance of information available concerning these three facilities permitted the Review Group to make it.s rating.

1 TABLE 1 RATINGS FOR OPERATING POWER REACTOR FACILITIES Operating Period of Regional Facility Utility SALP Board Evaluation Above Average raciliti_es es Cooper ~

Nebraska Public Power 1/1/79 - 8/6/80 District Farley Unit 1-Alabama Power Company-5/1/79 - 4/30/80' Unit 2 4/1/79 - 3/30/80 Fort Calhoun Omaha Public Power District 1/1/79 - 6/30/80 Millstone 1 & 2 Northeast Nuclear Energy 7/1/79 - 7/1/80 Company Oconee 1, 2 & 3

. Duke Pcwer Company 5/1/79 - 4/30/80 Point Beach 1 & 2 Wisconsin Electric Power 11/1/79 - 19/31/80 Company Prairie Island 1 & 2 Northern States Power 9/1/79 - 8/31/80 Cor?any -

Vermont Yankee Vermont Yankee Nuclear 5/1/79 - 5/1/80 Power Corporation Yankee Rowe Yankee Atomic Electric 5/1/79 - 5/1/80-Company 2

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Average Facilities Big-Rock Point Consumers Power Company 9/1/79 - 9/30/80 Calvert Cliffs 1 & 2 Baltimore Gas & Electric 10/1/79 - 9/30/80 Company D. C. Cook 1 & 2-American Electric Power 10/1/79 - 9/30/80 Service Corporation Dresden 1, 2 1 3 Comnonwealth Edison Company 7/1/79 - 6/30/80 Duane' Arnold Iowa Electric Light and 9/1/79 - 8/31/80 Power ft. St. Vrain Public Service Company 10/1/79 - 10/1/80 of Colorado Ginna-Rochester Gas and Electric 1/1/79 - 5/2/80 Corporation Haddam Neck Connecticut Yankee Atomic 6/1/79 - 6/1/80 Power Company Hatch 1 & 2 Georgia Power Company 4/1/79 - 9/30/80

. Indian Point 3 Power Authority of the 2/1/80 - 1/31/81 State of New York Kewaunee Wisconsin Public Service 11/1/79 - 11/31/80 Corporation La Crosse Dairyland Power Cooperative 8/1/79 - 7/31/80 Maine Yankee Maine Yankee Atomic-Power 9/1/79 - 8/31/80 Company McGuire 1 Duke Power Company 5/1/79 - 4/30/80 Monticello Northern States Power 10/1/79 - 9/30/80 Company North Anna 1 & 2 Virginia Electric and 5/1/79 - 4/30/80 Power Company

TABLE 1 (continu:d)

-Operating Period of Regional

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- FaciIity Utility-SALP Board Evaluation Average Facilities (continued)-

Peach Bottom'2 & 3

' Philadciphia Electric 5/1/79 - 5/1/80-Company Quad Cities 1 &-2--

Commonwealth-Edison 7/1/79 - 6/30/80-Co npany

. H. B.. Robinson 2 Carolina Power and 4/1/79 - 5/30/80' Light Company San Onofre 1-

- Southern California 5/15/79 - 5/15/80 Edison Company

.Sequoyah l' Tennessee Valley

- 8/1/79 - 3/29/80 s

Authority St. Lucle~1-Florida Power and 5/1/79 - 4/30/E0 Light Company

. Three Mile Island 1-Metropolitan Edison 4/1/80 - 3/31/81 Company-Trojan Portland General 9/1/79 - L/31/80 Electric Company

- Turkey _ Point 3 & 4

- Florida Power and-5/1/79 - 6/30/80 Light Company.

Zion 1 & 2 Ccmmonwealth Edison 7/1/79 - 6/30/80

' Company Below Average Facilities Arkansas 1 & 2 Arkansas Power and 1/1/79 - 8/19/80 Light Company Beaver Valley 1 Duquesne. Light Company 9/1/79 - 8/31/80 Browns Ferry 1, 2 & 3

--Tennessee Valley

- 4/1/79 - 3/31/80 Authority

' Brunswick 1 & 2 Carolina Power and Light 4/1/79 - 3/31/80 3

Company Cyrstal River 3' Florida Power Corporation 5/1/79 - 4/30/80 Davis-9 esse Toledo Edison Company 11/1/79 - 10/31/80 FitzPatrick Power Authority of the State 12/1/79 - 11/30/80 of New York

_ indian Point 2 Consolidated Edison Company 1/1/80 - 12/31/80 Nine Mile' Pol 7t l' Niagara Mohawk Power 2/1/80 - 1/31/81'

_ Corporatic Oyster Creek Jersey Central Power and 8/1/79 - 7/31/80 Light Ccmpany Palisades Consumer Po.ser Company 9/1/~9 - 9/1/80 t

. Pilgrim _

Boston Edir.on Company '

1/1/80 - 12/31/80 i

Rancho Seco Sacramento Municipal 4/15/79 - 4/15/80 Utility District 1

Public Service Electric 9/1/79 - 8/31/80 Salem 1 & 2 and Gas Conipany Surry l'& 2 Virginia Electric and 5/1/79 - 4/30/80 Power Company

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. RATINGS FOR 'POWERL REACTOR FACILITIES U"0ER CONSTRUCTION Operating Period of Regional Facility Utility SALP Poard Evaluation Average Facilities

. Beaver Valley 2 Duquesne' Light Company 3/1/80 - 2/28/81

=Bellefonte 1 & 2 Tennessee Valley 4/1/79 - 6/30/80 Authority Braidwood 1 & 2 Commonwealth Edison Company 7/1/79 - 6/30/80 Byron'1 & 2 Commonwealth Edison Company 7/1/79 + G/30/80 Callaway 1 & 2 Union Electric Company 7/1/79 - 6/30/60 Cherokee 1, 2.& 3 Duke ~ Power Company 9/1/79 8/31/80 Clinton 1 & 2 Illinois Power Company.

//l/79 - 6/30/80 Cocmanche Peak 1 & 2 Texas Utilities Generating 8/1/79 - 7/31/80 Company Diablo Canyon 1 & 2 Pacific Gas and Electric 7/1/79 - 12/31/80 Company Fermi 2 Detroit Edison Company 7/1/79 - 6/30/80 Grand Gulf Mississippi Power and 9/1/79 - 8/31/80 Light Company Hartsville A1, A2, B1, Tennessee Valley 4/1/79 - 6/30/80

- & B2 Authority Hope Creek 1 & 2 Public Service Electric 11/1/79 - 10/31/80 and Gas Company LaSalle 1 & 2 Commonwealth Edison Company 7/1/79 - 6/30/80 Limerick 1 & 2 Philadelphia Electric 10/1/79 - 9/30/80 Company McGuire 2 Duke Power Company 9/1/79 - 8/31/80 Millstone 3 Northeast Nuclear Energy s/1/80 - 2/28/81 Company Niagara Mohawk Power 2/1/80 - 1/31/81 Nine Mlle Point 2 Corporation Palo Verde 1, 2 & 3-Arizona Public Service 6/1/79 - 5/31/80 Company Perry 1 & 2 Cleveland Electric 7/1/79 - 6/30/80 Illuminating Company Phipps Bend 1 & 2 Tennessee Valley 4/1/79 - 6/30/80 Authority River Bend 1 & 2 Gulf States Utilities 9/1/79 - 8/31/80

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Company San Onofre 2 & 3 Soutnern California 6/1/79 - 6/30/80 Edison Company Seabrook 1

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Public Service Company 1/1/80 - 12/31/80 of New Hampshire Sequoyih 2 Tennessee Valley 8/1/79 - 7/31/80 Authority Shearon Harris 1,2,3 & 4 Carolina Power er.d Light 9/1/79 - 8/31/80 Company Shoreham Long Island Lighting 3/1/80 - 2/28/81 Company St. Lucie 2 Florida Power and Light 9/1/79 - 8/31/80 i.

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TABLE 2 (continu:d)

Operating Period of Regional Facility Utility SALP Board Evaluation Average Facilities (continued)

Summer South Carolina Electric 9/1/79 - 8/31/80 and Gas Susquehanna 1 & 2 Pennsylvania Power and 1/1/80 - 12/31/80 Light Company Vogtle 1 & 2 Georgia Power Company 5/1/79 - 8/31/80 Waterford 3 Louisiana Power and Light 8/1/79 - 7/31/80 Company Washington Nuclear Washington Public Power 5/29/79 - 7/18/80 Projects 1/4 Supply System Washington Nuclear Washington Public-Power 8/1/79 - 8/31/80 Projects 3/5 Supply System Wolf Creek Kansas Gas and Electric 8/1/79 - 7/31/80 Company Yellow Creek 1 & 2 Tennessee Valley 4/1/79 - 6/30/80 Authority Below Average Facilities Catawba 1 & 2 Duke Power Company 9/1/79 - 8/31/80 Marble Hill 1 & 2 Public Service of 7/1/79 - 6/30/80 Indiana Midland 1 & 2 Consumers Power 7/1/79 - 6/30/80 Company South Texas Project 1 & 2 Houston Lighting and Power 8/1/79 - 7/31/80 Company Washington Nuclear Washington Public Power 4/1/79 - 4/1/80 Project 2 Supply System Watts Bar 1 & 2 Tennessee Valley 8/1/79 - 7/31/80 Authority Zimmer Cincinnati Gas and 10/1/79 - 9/30/80 Electric Company

APPENDIX A PERFORMANCE Elt?.ENT SUMMARIES FOR OPERATING POWER REACTOR FACILI1![5 FAIED AB0VE AVERAGE OR BELOW AVERAGE INTRODUCTION This appendix contains' performance element summaries for operating power-reactor facilities rated above average (Part 1) or below average (Part 2) by I

'the SALP. Review Group.

The summaries are provided alphabetically by facility.

The evaluation periods are those used by the Regional SALP Board.

Areas of weakness were identified at various facilities during the SALP. These weaknesses were discussed with the respective licensee management organizations and improvements in these areas are expected from licensee corrective actions already taken or initiated.

PART 1 - ABOVE AVERAGE OPERATING POWER REACTOR FACILITIES l

Cooper Evaluation Perior.

1/1/79 - 8/6/80 Cooper was assessed to be a well-managed facility.

The licensee demonstrated an excellent record of refueling outage management.

The total number of items of noncompliance identified at Cooper was relatively low when compared with other operating reactor f acilities.

Due to the lev incidence of items of noncompliance, IE reduced the frequency of inspection effort in three areas (surveillance, training, and design changes).

The licensee's management was characterized as normally taking action that assured long-term resolution to problems.

Farley 1 & 2 Evaluation Perieds:

Unit 1 - 5/1/79 - 4/30/80 Unit 2 - 4/1/79 - 3/30/80 The Farley facility was assessed as having well-managed site and corporate organizaiions and a positive approach toward nuclear safety.

The total number of items of noncompliance identified.at Farley was relatively low when compared d

a

'with'o'ther operating reactor facilities.

The health physics appraisal inspec-tion revealed that FarleyLhad an above average radiation protection program.

The licensee was particularly thorough and responsive to the requirements for hanger and snubber inspections pursuant to IE Bulletin 79-14.

Although the

. licensee displayed weaknesses in the implementation of certain quality assurance i

program requirements, it was responsive in taking effective corrective action

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during the evaluation. period.

Fort Calhoun Evaluation Period:

1/1/79 - 6/30/80 Fort Calhoun was assessed to be a well-managed facility with the sr.nior licensee management and corporate engineering staff actively involved in the plant activities.

The licensee was responsive to NRC requests and displayed a parti-cularly positive attitude toward safet) requirements.

The total number of items of noncompliance identified at Fort Caihoun was relatively low when compared with other operating-reactor facilities.

Due to the low incidence of items of noncompliance, IE reduced the frequency of inspection ef fort in four areas p

of licensee activity (maintenance, surveillance, design changes, and committee

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activities).

The licensee maintained good communications with the NRC and

- between the various plant and corporate staf f organizations.

Licensee manage-

' ment stressed the need for high performance, 'imely identification and resolution of problems, and the retention of a technically competent staff f

-and operating organization.

Millstone 1 & 2 Evaluation Period:

7/1/79 - 7/1/80 The. Millstone facility was assessed to be well run with particularly competent andl responsive management.

The health physics appraisal inspection revealed that the utility.had a strong commitment to radiation protection.

The quality assurance program was better than the quality assurance program at most other

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operating reactors.

The licensee was very responsive in upgrading its security program to meet ~NRC requirements.

The total number of items of noncompliance A-2

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4 identified.at Millstone _was!relatively7 low when compared with other operating.

n t reactor' facilities.

The licensee displayed vaakness only in the area of

. personnel adherence to procedures.

!!nwever, the licensee was responsive to NRC concern; in this area.

0conee 1, 2 & 3 Evaluation Period

5/1/79 - 4/30/80

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- OconeeLwas assessed to have particu'arly competent site and corporate organ-l izations.

The licensee maintained' good communications with the NRC.

The total number of; items'of noncompliance identified at Oconee was relatively low when compared with other operating reactor facilities.

The health physics

[

appraisal' inspection revealed that the licensee's radiation protection program

'as better than most licensees.

Facility. management was unusually responsive w

"to NRC4 requirements, findings of noncompliance, and information requests.

j Although the licensee displayed weaknesses in personnel adherence to operating and administrative procedures, the licensee was responsive to NRC concerns in i

this: area.

I I

Point Beach 1 & 2 Evaluation Period:

11/1/79 - 10/31/80 i

Point Beach was assessed to be well managed and to be backed by an unusually competent corporate organization.

Areas of above average performance included operations,. radiation protection, and emergency. planning.

The total number of

-items of noncompliance at Point Beach was relatively low when compared with other

' operating reactor. facilities.

The licensee was particularly responsive-in taking corrective action to issues involving personnel error.

The health physics appraisal inspection found the licensee's radiation protection program h

. to be better than most licensees inspected.

The licensee's management posi-

tively and vigorously addressed the need for high performance and resolution-

of problems.

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i Prairle Island 1 & 2 Evaluation Period':

9/1/79 - 8/31/80

. Prairie Island management was= assessed as having a high level of competence.

and experience.. Areas of above average performance included operations, radiation protection, and environmental protection.

The facility management positively and vigorously addressed the need for high performance and tasol-j ution of. problems.

Licensee technical responses to NRR requests were above average and indicated a highly competent licensing and plant staff.

The health physics appraisal inspection found the licensce's radiation protection w

L program to be better than most licensees inspected.

The total number of items of noncompliance identified at Prairie Island was relatively low when compared "with other operating reactor facilities.

The licensee had more items of noncompliance in the security area than some licensees considered to be above l

l average, but the licensee's corrective act. ions and improved performance trend

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during'the evaluation period demonstrated strong management attention to this area.

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Vermont Yankee Evaluation Period:

5/1/79 - 5/1/80-I L

Vermont Yankee was asses,ed to have technically competent and responsive site f

and. corporate management organizations.

The licensee was responsive to regu-latory isc w and was attentive to anticipating problems.

The total number of j

ltems of norgumpliance identified at Vermont Yankee was relatwely low when i

compared with other operating reactor fx llities.

The licensee received one noncompliance of the " violation" category, rut it involved an isolated incident and did not reveal an overall breakdown in management controls. This incident co;.merned a packuge of low specific-activity material released to the carrier with a radiation level that exceeded the allowable limit.

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Yankee Rowe Evaluation Period:

5/1/79 - 5/1/80 Yankee Rowe was assessed to be a well-managed facility.

The experience level of the licensee staff, combined with r,trong administrative controls, resulted in a low number of personnel errors.

The total number of items of noncompliance identified at Yankee Rowe was relatively low when compared with other operating reactor facilities.

Yankee Rowe displayed no evidence of any programmatic weaknesses.

The licensee has demonstrated a high degree of responsiveness to NRC safety concerns.

PART 2 - BELOW AVERAGE OPERATING POWER REACTOR FACILITIES Arkansas Nucleaa One Units 1 & 2 Evaluatior, Period:

1/1/79 - 8/19/80 The Arkansas Nuclear One facility displayed evidence of weaknesses in the

?s of training, security, reporting, and quality entrol.

c Portions of the licensee's training plan were not implemented and portions of the requalification training program were not accomplished.

Several items of noncompliance were identified, a civil penalty was subsequently levied, and 11censee management meetings were held to correct training weaknesses. Numerous noncompliances were identified in t9 security area.

There were weaknesses in the training of security personnel und other members of the plant staff regarding security requirements.

Instances were identified in which licensee audits of security prog ams were not sufficient to identify discrepancies.

The licensee hired a new security contractor in mid-1980. The reporting area was characterized by several licensee event reports that were late or incomplete.

Quality control weaknesses precluded the licensee from identifying and correcting some discrepancies that were subsequently identified by the NRC.

f Arkansas Nuclear One received a relatively large number of items of noncom-pliance when compared with other facilities.

A performance appraisal team l

inspection identified several areas of lia m ee activity needing improved A-5

gs management' controls.

The licensee had weaknesses in the. staff support of licensing activities..Since~early 1980, changes in the utility's-licensing organization resulted:in Significant improvements in this area.

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' Beaver Valley l' Evaluation Period:

9/1/79 - 8/31/80 The Beaver Valley 1 facility displayed evidence of weaknesses in nine functional area *. These areas were plant operatior.s, maintenance, surveillance, quality assurance, committee activities, fire protection, derign changes and modifica-tions, security, and manar.ement controls.

A. low corporate engineering staff manning level led to a lack of design control over some contractor activities.

The onsite safety review committee was over-burdened and some reviews were inadequate.

Management control problems involved i

i control of routine activities, resolution of technical and regulatory. concerns, correction of deficient areas, implementation of security plan requirements,

(

and scheduling of required surseillance activities.

Beaver Vallev init 1-received a relatively large number of items of noncom-

. pliance,.inc'ud'ng escalated enforcement action, when compared with other facilities.

There were frequent meetings and contacts with this licensee regarding the conduct of safety related activities.

Many items of noncom-pliance concerned personnet errors, indicated instances of insufficient training, and revealed instances of poor supervision of persbnnel.

The licensee experienced difficulties in meeting some technical commitments to NRR

.and lacked an adequate technical support staff.

Browns Ferry 1, 2, & 3 Evaluation Period: 4/1/79 - 3/31/80 i

The Browns Ferry-facility displayed evidence of weaknesses in the areas of radiation protection, reporting, and management control.

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- Radiation' protection weaknesses'were characterized by numerous noncon.pliances, weaknessesDin exposure' controls, and instances when1 licensee personnel _ failed-to follow procedures.

Reporting-weaknesses were characterized by instances of

' licensee event reports that were incomplete and failed to consider implications

[

- In other areas. Management control weaknesses contributed to a loss' of Unit 3 primary containment integrity on December 6-9, 1979, while the reactor was at power.

This violation of technical specifications resulted in escalated

- enforcement action.

Management control weaknesses also included instances of_ missed sur"eillances, procedure adherence errors, and misoriented fuel assemblies that were not discovered during post-refueling core load I

verifications.

Browns Ferry received an average number of items of noncompliance when compared-

't with other facilities.

However, the licensee's below average performance in areas where the facility received msny items of noncompliance was considered to be an important contributor to the overall below average performance rating.

i Brunswick 1,j(_2 Evaluation Period:

4/1/79 - 3/31/80 The Brunswicx facility displayed evidence'of weaknesses.in the areas of radia-tion control, contamination control, and environmental protection.

l The inadequate nanagement control over radiation exposure and contamination l

resulted'in unmonitored and uncontrolled release of airborne radioactive material.

Management control weaknesses also resulted in the improper release

- of licensed material to a sanitary landfill and local sa',vage dealer.

Brunswick management control weaknesses were characterized by numerous noncompliances y

concerning the quality assurance program (some of which were repetitive),

problems in supervisory overview and the conduct of cenmittee activities, and f~

instances of activities conducted without procedures.

The IE performance appraisal team found significant weaknesses in areas involving management overview,. training, and corrective actions.

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Brunswick received an average number of items of noncompliance.

However, an

- Immediate Action Letter was issued concerning_ inadvertent release of radio-tactivity to unrestrict'ed areas.

i Crystal giver 3 Evaluation Period:

5/1/79 - 4/30/80 The Crystal River 3_ facility displayed evidence of weaknesses in four functional

. areas.

These areas were emargency planning, plant operations, training, and radiation protection.

The-licensee had problems meeting the requirements of its emergency plan.

i-These problems have been resolved by the implementation of the new emergency plan.

The plant operations area was characterized by numerous items of non-complian w and instances-where operators failed to adhere to plant procedures, i

conducted activities _without procedures, or changed procedures without con-ducting the required reviews. Training program weaknesses contributed to pers'onnel errors and items of.. noncompliance.

Required training activities were not completed on several occasions.

The radiation protection area was characterized by numerous items of noncompliance, weaknesses in the exposure and contamination control programs, and inadequate control over liquid and

- solid radioactive waste.

- Crystal River 3_ received a relatively large number of items of noncompliance,

- including escalated enforcement action, when comp:' red with other facilities.

During_the. evaluation period, the licensee initiated organizational and staffing changes to provide a higher level of management attention and a greater resource allocation to deal with identified problem areas.

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Davis-Besse Evaluation Period:

11/1/79 - 10/31/80-4

- The Davis-Besse facility displayed evidence of weaknesses in the areas of

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security and plant operations.

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The security area'was_ characterized by numerous items of noncompliance

.resulting in several enforcement conferences between the NRC and licensee management. Weaknesses in both corporate and site security management-control contributed to difficulties in the maintenance of security-related equipment.

Performance in the area of plant operations was variable with some evidence of improvement near the end of the evaluation period.

Plant operations during the evaluation period were characterized by instances of

~

Lpersonnel_ errors and failure to follow' procedures, staffing problems, repetitive equipment problems, and problems in managing facility changes and modifications.

This resulted in a series of management level meetings between the NRC and the-licensee.

Some of the problem areas identified prior to the-evaluation period were still in the process of being corrected by the, licensee.

Instances were identified where nonlicensed members of the plant staff had insufficient training.

The licensee's program to upgrade the experience level of nonlicensed members of the shift operating crews was :onfirmed by an NRC Order.

3 A,t';m:gh responsive to most SRC concerns, the licensee responses to IE Bulletin 6d-06 (Engineered Safety Feature Reset Controls) and to Three Mile Island -

Lessons Learned - Category A items indicated a problem in management coord-ination and attention.

The retponses were either incomplete or not compre-hensive; therefore requiring revisions or submi tal of additional information.

t Davis-Besse received a relatively large number of'noncompiiances when compared to other facilities.

The majority of the noncompliances were in the security area..The licensee also received a civil penalty as a result of an individual overexposure that occurred in April 1980.

I.

i A performance appraisal team inspection, completed in November 1980 but covering I

the evaluation period, revealed average and above average performance in sev-eral areas, especially training.

The inspection revealed a significant weak-ness only in the area of procurement of safety-related components.

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e FitzPatrick

. Evaluation Period:

12/1/79 - 11/30/80-The FitzPatrickLfacility displayed evidence of weaknesses in eight functional

~ arecs.

These areas were fire _ protection, design changes and modifications,

-radiation protection, emergency preparedness, radioactive waste management, transportation, security and safeguards, and management contrcls.

~ The fire' protection area was c.haracterized by several items of noncompliance and a failure to meet housekeeping commitments.

There were' instances where the licensee had not made program revisions to the design change and modifi--

cation area in accordance with commitments to the NRC.

Weaknesses in radiation y

protection, emergency preparedness, and radioactive waste management were identified during routine NRC inspection efforts and during the health physics appraisal inspection.

In these areas there were instances of weaknesses in procedures, inadequate training, and rersonnel errors.

The NRC issued an j

Immediate Action Letter to confirm the licensee's commitments to resolve l weaknesses identified during the health physics appraisal. Weaknesses in security and safeguards identified duriig NRC inspections precipitated esca-lated enforcement action by the NRC, including a civil penalty and an Immediate i

Action Letter.

I fitzPatrick received a relatively large number of items of noncompliance,

)

including escalated enforcement action, when compared with other facilities.

During the evaluation period, the licensee's corporate management organitation was strengthened by a management reorganization and by the addition of personnel to the' corporate staff.

4 Indian Point 2 Evaluation Period:

1/1/80 - 12/31/80 The' Indian Point 2 facility displayed evidence of weaknesses in five functional i

areas.

These areas were plant operations, maintenance, reporting, committee activities, and management controls.

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i Most of the Indian Point 2. weaknesses were linked to the containment flooding incident that' occurred October 17,.1980.

The NRC investigation of this event revealed eleven items of noncompliance and resulted in escalated enforcement

- action.

The plant operations area was characterized by instances where the.

licensee made improper assignments of supervisory personnel'and failed to

~

. follow procedures.

Review of the maintenance area revealed instances where.

5the licensec failed to determine the causes of= repeated equipment malfunctions and instances of incomplete maintenance actions.

lhe licensee failed to submit several required reports to the NRC.

The licensee's Station Nuclear Safety Committee failed to make reviews of stecral safety-related events and activities that involved the potential existence of an unreviewed safety question, as de-fined in 10 CFR 50.59(e).

Further indications of weaknesses in the management

-controls area were identified as a result of the health physics appraisal and the licensee's approval of a procedure which disabled the automatic start feature of_the containment spray system.

Indian Point 2 received a relatively large number of items of noncompliance, including escalated enforcement action, when compared with other facilities.

J Nine Mile Point 1 Evaluation Period:

2/1/80 - 1/31/81 i

The Nine Mile Point 1. facility displayed evidence of weaknesses in four functional arpas.

These areas were:

radiation protection, emergency preparedness, radio-i active waste management, and rnanagement controls.

i

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'The radiation protection area was characterized by items of noncompliance and inadequacios-in major areas of the licensee's health physics program.

Escalated enforcement action was taken to asttre licensee corrective actions.

The licensee had significant weaknesses in the areas of emergency preparedness and radioactive waste management, An inadequate installation prevented full com-pliance with'the' requirements for an increased range radiation nonitor pursuant

'to the short term requirements of the iMI Lessenc Learned.

Licensee manage--

ment failed to properly identify, correct and report this inviequate installation i

A-11

which resulted in escalated enforcement action by the NRC.

Subsequently, the:

11censee'made significant changes in the management controls concerrfing radiation protection, emergency preparedness, and radioactive waste managemer,t.

'Nine Mile _ Point-1 received-a relatively large number of items of. noncompliance, including escalated eaforcement action, when compared with other facilities.

~0yster Creek Evaluation Period:

8/1/79 - 7/31/80 i

-The Oyster Creek facility displayed evidence of weaknesses in the areas of

. radiation protection and radioactive waste mat.gement.

Problems with implementation of radiation protection and radioactive waste programs -resulted in identification of numerous items of nc~ompliance, including escalated enforcement action.

The licensee's use of health physics technicians not fully meeting the requirements of ANSI N18.1-1971 resulted-in the _ issuance of. an NRC 'Irder modifying the facility license to correct this I

inadequacy.

The plant review committee failed to require audits of the health physics area and portions of the plant staff training program. There were instances where the licensee failed to meet commitments made to the NRC.

There were instances where licensee personnel failed to adhere to procedures, resulting 4

in several items of noncompliance.

i Early in the assessment period, the' IE Performance Appraisal Teum rated seven

.of-fifteen designated areas as below average (then defined as poor).

These areas were fire protection, training, iaservice inspection and testing, main-tenance, QA audits, radiation protection, ar.d radioactive waste management.

Similar inadequacies, with improvement noted, were identified later during the assessment period by the health physics appraisal team inspection and during routine Regional inspu tions.

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Oyster Creek received a relatively large number of items of noncompliance, including escalated' enforcement action, when compared with other facilities.

The licensee initiated organizational changes to provide direct management attention and resource allocation to identified problem areas.

Palisades Evaluation Period:

9/1/79 - 9/1/80 The Palisades facility displayed evidence of weaknesses in the areas of plant operations, surveillance, and radiation protection.

Performance in the area of plant operations was characterized by personnel errors and failure to follow procedures.

Repetitive instances of system misalignments impaired ECCS equipment operability and containment integrity.

The licensee had numerous problems with defective plant operating procedures.

There were instances where the licensee had difficulty.in completing adequate corrective action for identified discrepancies. Weaknesses in the surveillance area were characterized by instances of defective procedures and personnel errors.

I In the radiation protection area, there were items of noncompliance regarding personnel overexposure and iaadequate controls over release of radioactive materials.

In addition, the health physics appraital team inspection found Palisades radiation protection programs to be below average.

There were weaknesses in training and staffing, exposure control, procedure and QA program iruplementation, and instrumentation availability.

Palisades received a relatively large number of items of noncompliance when compared with other facilities.

Escalated enforcement action was taken on l.

several occasions.

The licensee initiated corrective action prior to and during the evaluation period to improve performance.

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Pilgrim Evaluation Period:

1/1/80 - 12/31/80 The Pilgrim facility displayed evidence of weaknesses in five functional areas. These areas were:

refueling, reporting, radiation protection, emergency preparedness, and management controls.

Weaknesses in refueling activities were characterized by several items of noncompliance, including escalated enforcement, concerning movement of fuel j

without secondary containment integrity and inadequate corrective actions for identified procedure discrepancies.

The licensee had cases of inadequate and i

incomplete Licensee Event Reports and responses to IE bulletins.

The radiation protection program was characterized by numerous items of noncompliance and program weaknesses, many of which were identified during the health physics appraisal team inspection.

Escalated enforcement was taken to correct iden-tified weaknesses and inadequacies in several emergency response procedures.

Licensee management control weaknesses were indicated by inadequate evaluation of several events to prevent recurrence, instances of inadequate corrective I

actions, and instances of inadequate implementation of cc:rmitments made to the NRC.

A!though Pilgrim received an average number of items of noncompliance, there were instances in which escalated enforcement action was taken to assure corrective action by the licensee.

In September 1980 the licensee imple-mented major organization and personnel changes as a resnonse to NRC concerns.

Rancho Seco Evaluation Period:

4/15/79 4/15/80 The Rancho Seco facility displayed evidence of weaknesses in the functional areas of quality assurance audits, quality control inspections, training, and operations.

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Weaknesses in-the area of quality assurance audits were indicated by instances of-audits:not performed, inadequate respons'e to audit findings, and audits Llacking sufficient depth and scope.

Quality control inspections were insuf-ficient to assure control over so%e safety-related maintenance activities.

~

Training requirements.were not fully implemented for nonlicensed personnel.

Operations area weaknesses were characterized by instances-of failure to align systems or components properly, and personnel errors.

Escalated enforcement

_ action was'taken to assure licensee corrective action following the discovery of an emergency core cooling system misalignment following maintenance.

-Although. Rancho Seco received an average number of items of noncompliance,

' management control weaknesses were identified in several areas at licensed i

activity.

The Performance Appraisal Branch inspection identified seven, out of eleven, areas of management activity that had significant weaknesces.

These areas were committee activities, quality assurance audits, design changes and modifications, maintenance, corrective action system, nonlic9nsed

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personnel training, and fire prevention.

Salem 1 & 2 Evaluation Period:

9/1/79 - 8/31/80 The. Salem facility displayed evidence of weaknesses in four functional areas.

These areas were' plant operations, reporting, security and safeguards, and 1

. management controls.

l Weaknesses in plant operations were characterized by instances of failure to 1

-operate in accordance with plant procedures and instances of violation of Technical Specification limitations.

There were repeated cases where the licensee failed to complete required surveillance tests.

Licensee reports were late, inaccurate, or incomplete on several occasions.

There were

. problems in maintaining security contrels between Unit 1, which was operating, and Unit 2, which was still under construction and subject to different security A-15

requirements than an operating facility.

Although the station' staff demon-strated an ability to identify problems and propose solutions, there were instances where corporate management did not provide a timely response.

15alem received a relatively large number of items of noncompliance, including escalated enforcement action, when compared with other facilities.

The licensee has.taken or initiated corrective action for identified items of noncompliance.

Surry 1 & 2 Evaluation Period:

5/1/79 - 4/30/80 4

The'Surry facility displayed evidence of weaknesses in the areas of plant operations, radiation protection, and quality assurance.

Weaknesses in the operations area were characterized by repetitive instances of failure to follow procedures, improper system lineups or tagging errors, and unapproved use of temporary hoses or jumpers.

The licensee experienced difficulty _in responding to unplanned maintenance problems, failed to take corrective actions in response to several recurring problems, and did not adequately test equipment following maintenance on several occasions. Weak-nesses in the radiation protection area were indicated by numerous radiation i

l protection items of noncompliance and escalated enforcement action concerning inadequate radiological surveillance on a radioactive waste shipment.

Quality assurance weaknesses were characterized by instances of longstanding and un-corrected design problems in plant systems, instances where the licensee used unqualified _ parts in safety-related maintenance, and several procedures that were not properly revised following ter.hnical specification revisions.

Although the facility received an average number of items of noncompliance, there was one instance where escalated enforcement action was taken to assure corrective action by the licensee.

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APPENDIX B l

PERFORMANCE ELEMENT SUMARIES FOR POWER REACTOR j

FACILITIES UNDER CONSTRUCTION RATED BELOW AVERAGE INTRODUCTION Thic, appendix contains performance element summaries for power reactor facili-ties under construction rated below average by the SALP Review Group.

No reactors under construction were rated above average.

The summaries are provided alphabetically by facility.

The evaluation periods are those used by the Regional SALP Board.

Areas of weakness were identified at various facilities during the SALP.

These weaknesses were discussed with the respective licensee management organizations-and improvements in these areas are expected from licensee corrective actions already taken or initiated.

Catawba 1 & 2 Evaluation Period:

9/1/79 - 8/31/80 The Catawba _ facility displayed evidence of weaknesses in the area of quality assurance, including management and training.

Quality assurance weaknesses were characterized by instances-of inadequate design reviews, procedures not issued, specifications and commitments not translated into procedures, and audit programs not established.

There were numerous items of noncompliance involving failure to follow procedures for activities involving welding, concrete placewent, design, quality control insnections, records control, and electrical equipment installation Catawba received a relatively large number of ib'ms of noncompliance when compared with other power reactor facilities-under construction.

Most of these items of noncompliance were attributed to weakness in the licensee's quality assurance and management overview process.

Marble Hill 1 & 2 Evaluation Period:

7/1/79 - 6/30/80 Although construction at the Marble Hill facility was shut down by the NRC for most of the evaluation period, the licensee's activities prior to and during the early part of the evaluation per cd displayed eviderce of project engineering, quality assurance, and construction management weaknesses.

The licensee had not sufficiently implemented quality assurance and management controls.

There were ineffective controls over civil and mechanical construc-tion as well as stored equipment and components.

Quality control inspections by contractor personnel were not performed effectively.

Conditions adverse to quality were not corrected prior to concrete placement.

Corrective actions were not taken for discrepancies.

Marble Hill received a relatively large number of items of noncompliance when compared with other power reactor facilities under construction.

There were instances where the licensee required escalated NRC enforcement action, fre-quent management contacts, and stop work orders to assure compliance with NRC requirements.

An Order suspending all safety-related work was issued in August 1979, because of NRC concerns over the adequacy of the licensee's quality assurance program and controls over construction activities.

Licensee actions were taken during the evaluation period to obtain NRC approval of the resumption of safety-related work.

These included staffing and organizational changes, quality assurance program development, and the identification and resolution of problems.

Incremental resumption of safety-related construction, subject to the approval of the NRC, commenced subsequent to the evaluation period.

Midland 1 & 2 Evaluation Period:

7/1/79 - 6/30/80 The Midland facility displayed evidence of weaknesses in three functional areas. These areas were quality assurance (including management and training),

substructures and foundations, and safety-ralated components.

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In the area of quality assurance there were numerous items of noncompliance, instances o' unqualifieu QC inspectors,'and instances of inadequate control of contractor activities.

Earlier quality assurance problems assc:iated.with materials and placement of soils and backfills were identified during the evaluation period.

The licensee was slow in responding to NRC concerns regarding soil placement. An NRC Order modifying the construction permit was issued to assure corrective action to the soil problems.

Major defi-ciencies-were identified in quality assurance controls over the installation of safety-related heating, ventilating, and W -conditioning components.

hase deficiencies'resulted in the issuance of an NRC stop work order and the imposi-tion of civil penalties to assure corrective action.

Technical responses to NRR were occasionally inadequate but have shown improvement during the evaluation period.

Midland received a relatively large number of items of noncompliance when compared with other power reactor facilities under construction.

During the evaluation the licensee initiated action that allowed a reorganization to be implemented in August 1980.

South Texas Project 1 & 2 Evaluation Period:

8/1/79 - //31/80 The South Texas Project facility displayed evidence of management weaknesses in the areas of quality assurance and overall construction management.

A Regional SALP Board review and licensee meeting was not held as part of the South Texas Project evaluation.

The Review Group examined investigation and inspection reports,_and other data relevant to the evaluation period, in rating the South Texas Project facility.

The licensee had not sufficiently implemented quality assurance and management controls.

Personnel training regarding quality assurance was inadequate.

Con-struction pressures thwarted quality control functions. There were threats, harassment, and intimidation of quality control inspectors, and the licensee (whn was knowledgeable of these problems) failed to take effective corrective B-3

action.

There were numerous instances of failure to fallow procedures in the areas of document control, material storage, concrete placement, and welding.

' Audit and surveillance programs were improperly implemented.

.The licensee had a breakdown in the implementation of the quality assurance program and management controls for safety-related concrete pours and safety-related welding.

Extensive NRC investigation of licensee activities resulted in numerous items'of noncompliance, escalated enforcement, frequent management contacts, and an NRC Show Cause Order to assure compliance with NRC require-ments.

Incremental resumption of safety-related concrete placement and welding has been subject to the approval of the NRC.

Washington Nuclear Project No. 2 Evaluation Period: 4/{/79 - 4/1/80 The Washington Nuclear Project No. 2 (WNP-2) facility displayed evidence of weaknesses in six functional areas.

These areas were quali'~ assurance (in-cluding management and training), safety-related structuru. piping and hangers, electrical equipment, electrical (tray and wire), and instrumentation.

The area of quality assurance was chcractu ezed by ineffective p:oo am imple-i mentation and inadequate control of contracter activities.

There were numerous items of nuncompliance involviq procedure and & awing adhere:1ce, control of special processes, and mainuaence of nuality assurance reerds.

The licensee had extensive difficulties in the installation of safety related pipe whip restraints, and in the erection and welding of the sacrificial shield wall 4

The NRC required the licensee to stco work reltted to these twc areas of w trc tion and took escalated enforcement action.

. WNP-2 rc elved a large number of items of noncampliance when compared with other power reactor facilites under construction licensee submittals to NRR displeved technical weaknesses and the licensee was not responsive to MC technical :.+yr*sts.on various occas ions.

The licensee received c< tensive NRC action (including escalated enft

.nent, frequent management contacts, and stop-work orders) to assure compliance with NRC requirements.

B-i

Watts Bar 1 & 2 Evaluation Period:

8/1/79 - 7/31/80

.The. Watts Bar facility oisplayed evidence of weaknesses in two areas.

These areas'were quality assurance (including management and training), and piping and hangers.

Quality assurance, management, and training weaknesses were characterized by numerous items of noncompliance and significant ' weaknesses in quality assurance

-program implementation.

There were many instances where licensee personnel failed to aohere to procedures.

There were instances where the licensee was U

unsuccessful in-achieving adequate corrective action ~to identified discrepancies.

The quality assurance organization and application of quality assurance was j

fragmented.

Difficulties in the installation of pipe hangers were characterized -

by instances of hangers in the wrong location, use of the wrong types of hangers, anchor bolt problems, and the use of incorrect materials.

Additionally, there were weaknesses in communications between varicus organizations within the Tennessee Valley Authority.

s Watts Bar received a relatively large number of items of noncompliance when compared with other power reactor facilities under construction.

There were several management contacts between the NRC and licensee management to assure problems were corrected.

Organizational changes were made in the quality assurance area subsequent to the Regional SALP review period.

Zimmer Evaluation Period:

10/1/79 - 9/30/80 The Zimmer facility displayed evidence of weaknesses in the areas of quality assurance management, piping and hanger suppoits,-and training.

The licensee had not adequately implemented quality assurance and management controls.

There were numerous items of noncompliance involving quality assur-ance criteria..There were instances where identification of problems and corrective actions were inadequate.

The quality assurance organization lacked aggressive and effective management.

There were itamerous instances of rejected B-5

1 l

work and continuing problems with the quality assurance aspects of piping and hanger supports installation.

There were items of noncompliance involving pro-cedure adherence and welding. The training area was characterized by inadequate staff, procedures that were not fully implemented, and lack of BWR operational experience in the training group.

Zimmer received a relatively large number of items of noncompliance, when compared with other power reactor facilities under construction.

i B-6

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Attachment i February 12, 1980

~ ~

UNITED $TATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 INFORMATION REPORT For:

The Commissioners From:

Victor Stello, Jr., Director Office of Inspection and Enforcement /n. '.

Thru:

Executive Director for Operations c,

Subiect:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Purcose:

The purpose of this paper is to inform the Commission regarding the status of efforts by the Office of Inspection and Enforce-ment in the evaluation of licensee performance.

Discussion:

In October 1978, IE submitted SECY 78-554 " Licensee Regulatory Performance Evaluation," which requested, and subsequently obtained, Commission approval for a two year trial program for evaluating licensee regulatory performance.

" Regulatory performance" was defined as the licensee's ability to meet regulatory requirements and to avoid reportable events.

SECY 78-554 indicated that an " integrated methocology" would be developed that incorporated selected aspects of the three previously considered methods (Statistical, Trend Analysis, and Regional Survey) that were described in the paper.

The objec -

tives of this methocology were oefined as:

l Icentification of factors that lead to different levels of regulatory performance; Effective and efficient use of NRC inspection resources; l

ano l

l Evaluation of various aspects of the NRC inspection program.

The trial program was develooed, but was never imolemented l

cecause of the Three Mile Island (TMI) Accioent.

A program for tne comorenensive overview of licensee performance nas been incluced as Task I.B.2 in the " Action Plans for l

Imolementing Recommenoations of tne Presicent's Commission anc

Contact:

H. D. Thornburg 49-28484

{

2-Other Studies of TMI-2 Accident" (NUREG-0660).

This program is described in the enclosed paper and is entitled " Systematic Assessment of Licensee Perfomance" (SALP).

The objectives of SALP are:

Identification of unacceptable licensee performance; Improvement of licensee performance; Improvement of IE inspection Program; Providing a basis for NRC management's allocation of resources; and Achieving regional consistency by appraising licensee performance from a national perspective.

The SALP Program has been developed for power reactor licensees, but may, with modifications, be applicable to major materials licensees.

As was the case with the Licensee Regulatory Performance Evaluation, the sat.7 Program is designed to identify licensees whose regulatory performance warrants increased emphasis in

-licensing and inspection activities.

If sucn licensees are identified, appropriate action will be initiated to upgrade the licensee. performance; a major thrust of the SALP.

The method-ology ha; five (5) basic features:

a

,a Eva h ation of licensee performance by a board of regional inspectors, regional supervisors, and the NRR Project Manager (NMSS Project Manager for Materials licensees);

Determination by regional management of the action necessary to upg Nde performance; Holding annual meetings with licensee management to discuss the regional ' evaluations and planned actions; e

+ Review of the evaluations of licensee performance and planned cohective action by a SALP Review Group, composed

, of senior-NRC managei::ent personnel, with inputs from the regional evaluations, NRR appraisals, and the appraisals of other NRC offices (i.e., AE00, PAB, etc. ); and Recommendations by the SN'.P Review Group to the appropriate

'NRC office director for cajor enforcement sanctions, license. modifications, or' increased (or decreased) inspec-tion emphasis (frequency or scope) as warranted by the licsnsee evaluations.

y 3

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. _ _ _ Selected portions of the three previously considered methods of performance appraisal have been incorporated into the regional evaluations of licensee performance.

An IE Manual Chapter (MC) defining the program for the regional evaluation of licensee performance is currently being reviewed by the regions.

This MC will be issued in March 1980.

Regional evaluations will begin in April 1980 and will be completed in June 1980.

The composition of the SALP Review Group, the procedures for Review Group operation, and details of the evaluations by the offices providing input to the Review Group, will be finalized by June 1980.

The initial evaluations of the SALP Review Group will be completed in December 1980.

Coordination: The Offices of Nucletr Reactor Regulation, Management and Program Analysis, Analysis 6.;d Cvaluation of Operat'onal Data, and Standards Development ccacur.

The Office of Nuclear Materit.1 Safety and Safeguards has no objection to the proposed program for reactor licensees.

The Executive Legal Director has no legal objecticas.

s Victor Stello, Jr.

Director l

Office of Inspection and Enforcement

Enclosure:

" Systematic Assessment of Licensee Performance" This paper is scheduled for consideration at an open meeting on February 14, 1980.

l i

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE L

INTRODUCTION This. paper describes the Systematic Assessment of L censee Performance (SALP) which is a refinement of a program previously eferred to as the

" Integrated Approach" to Licensee Regulatory Performance Evaluation (LRPE).

SALP, like LAPE, is defined as an evaluation of the ability of a licensee to meet regulatory requirements and to avoid significant events that appear to be directly under the control of the licensee.

The SALP Program was developed for pcwer reactor facilities in operation and construction, and is based on certain aspects of previourly conducted NRC studies, with the methods substantially modified.

The SALP Program, with modifications, may be applicable to major fuel facilities and major by product licinsed facilities.

The requirements for licensee perfomance appraisal were first established in NUdEG-0397, " Revised Inspection Program for Nuclear Power Plants",

which includes a national performance appraisal capability that provides the following elements:

Evaluation of the performance of NRC licensees from a national per-spective; Evaluation of the effectiveness of the NRC inspection program; and Confirmation of the objectivity of NRC inspectors.

During October 1978, IE submitted SECY 78-554, " Licensee Regulatory Performance Evaluation", to the Commission.

As described in f"CY 78-554, the objectives of LRPE were as follows:

Identification of factors that lead to different levels of regulatory performance; Effective and efficient use 'of NRC resources; and Evaluation of various aspects of the NRC inspection program.

SECY 78-554 described three methods (Statistical Method, Trend Analysis Method, and Regional Survey Method) of licensee performance appraisal which had been studied by NRC.

It also proposed the implementation of a trial program which was referred to as the " integrated approach" method-ology to Licensee Regulatory Performance Evaluation (LRFE).

This method-ology was to be used to evaluate operating reactor licensees using 1978-1979 data.

The trial program was developed, but its implementation was interrupted by the Three Mile Island Accident.

As a result of the investigative studies of the Three Mile Island Accident, a program for the comprehensive evaluation of licensee perfomance has l

been included as Task I.B.2 in the " Action Plan for Implementing Recoamendations of the President's Commission and Other Studies of TMI-2 Accident" (NUREG-0660).

The program outlined by Task I.B.2 is a refine-ment of the LRPE methodology.

This program which is the subject of this paper has been entitled the Systeratic Assessment of Licensee Performance (SALP) to coincide with the rccommendations of the Kemeny Report.

The objectives of SALP have been defined as:

Identification cf unacceptable licensee performance; i

l Improvement of licensee performance; Improvement of IE Inspection Program; l

Providing a basis for NRC management's allocation of resources; and Achieving regional consistency by appraising licensee performance from a national perspective.

i These objectives will be accomplished through the performance of periodic evaluations of licentees by IE and NRR.

The evaluations will be reviewed by a SALP Review Group of senior management personnel from NRC offices.

The results of the evaluations, the reviews by the SALP Review Group > and i

the plans for appropriate action by NRC will be documented and distributed to the appropriate office director, to the licensees, and to the Public Document Rooms.

In addition, the regional offices will hold annual management meetings with each of the evaluated licensees to discuss the results of the evaluations.

The appropriata action to upgrade licensee performance w: 0 be initiated by the regional offices as a result of the evaluations ar.d may include I

enforcement action, or increased inspection frequency and scope.

2.

INTEGRT.TED ASSESSMENT OF LICENSEE PERFORMANCE l

l a.

Procram Inoutss Several groups within the NRC will provide inputs to SALP as follows:

l (1) The IE regional office will perform an evaluation of the performance of each licensee semiannually.

This evaluation will be used to determine the need for an increase or decrease in the' frequency and scope of regulatory activities.

The region will document the results of the evaluation and their plans for action, and forward this documentation to the SALP Review Group.

(2) NRR Project Managers will participate in the regional evaluations discussed in (1) above.

The NRR Project Managers and technical support program personnel will also provide input

1 to the SALP Review Group.

In addition, NRR will perfort an independent study of the management capabilities and overall training of licensce egioyees.

The results of this study will be subuitted to the SALP Review Group for consideration during their initial evaluations.

(3) The IE Performance Appraisal Branch will perform Management Appraisal (MA) and Program Appraisal (PA) inspections at licenste facilities. The reports of their inspections will contain an appraisal of licensee management which will be forwarded to the SALP Review Group. All licensees will not receive these inspec-tions during the fir?t two years of this program.

However, it is expected that the number of licensees inspected will be sufficient to verify regional consistency.

(4) Other NRC Offices (such as AE90, etc) may provide input to the SALP Review Group as appraisal methodologies are developed with proven correlation to the safet; 'f operations.

The regional evaluation discussed in (1) above will utilize 4ppropriate portions of the three previously developed methods of performance evaluation.

The details of the above evaluation / appraisal techniques will be discussed in Section 3 of this paper.

b.

Review of Evaluation Results Review of NRC evaluation results and the appropriate plans for upgrading performance will be conducted by the SALP Review Group consisting of senior managers from the NRC offices appointed by the Executive Director for Operations.

The Review Group will provide an overview function of the evaluations and render an assessment of the safety adequacy of each facility and the adequacy of upgrading plans.

Based on the findings, the Review Group is specifically charged to recomsend major enforcement sanctions or license modifi-cations to appropriate office directors.

The Review Group will also confirm the consistency of regional evaluations and the regional implementation of NRC inspec' tion programs.

The SALP Review Group, in addition to receiving inputs from regional evaluations, will receive inputs from NRR, IE Headquarters, and from other NRC offices as appropriate.

The Review Group will convene at least once every six (6) months and revfew the evaluations of the licensees that are classified as needing " increased inspection scope /freque,cy." The remaining licensee evaluations will be eval-uated once every twelve (12) months.

c.

Feedback of Evaluation Results The primary cbjectives of SALP are to identify unacceptable elements of licensee performance and to subsequently improve (upgrade) licensee performance. The former objective is achieved by the regional

I

-4 evaluations and the reviews by the SALP Review Group, but to improve performance the results of these evaluations must be communicated to NRC management. The results of the regional evaluations and the recocmended plan for the appropriate corrective action is forwarded to the Regional Director for review and approval.

The results of the SALP Review Group are forwarded to the appropriate office director 3

indicating a concurrence with the proposed regional action or recom-mending additional or alternate action.

NRC offices pmvfding evaluation information will document the result.s of their evaluations with distribution to the licensee, PDR, and to the SALP Review Group.

In addition, the region will submit an interoffice memorandum detailing the future plans for action by the region to correct the deficiencies identified during the evaluation.

The Review Group will issue a report at the conclusion of their 3

periodic reviews to document the extent of their concurrence with the regional evaluations and proposed actions, or their recommenda-tions for additional or alternate action.

Annual ::eetings will be conducte.1 by regional management with the managements of the licensees evaluated by this program.

These meetings will be utilized to discuss the results of the licensee performance evaluations and the NRC's general plan of action for correcting deficiencies.

3.

METHCCOLOGIES a.

Regional Evaluation Each region will perform a detailed evaluation of their power reacw-licensees semiannually.

The evaluations will be performed by a board of the inspectors (including the resident in v etor) and supervisors involved in the inspection program for that licensee.

The board will also include the NRR Project Manager for the facility.

The board will consider the' enforcement actions, deficiency / event reports, technical and management performance, and safety attitudes of the licensee.

The evaluations will also be based on the observa-tions of the board members and their judgments of the licensee's performance.

The evaluation will be the board's consensus of I

licensee performance; however, dissenting opinions with substantive coments will be included and transmitted to the SALP Review Group for concurr'ent evaluation.

A number of functional areas will be evaluated by the board and a classification of " increase," " decrease,"

or "no-change" in the frequency end scope of inspection effort will be assigned for each functional area.

The board will also provide an overall evaluation of the licensee and a detailed plan of the appropriate actions to upgrade performance.

i i

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. - - - The evaluation of each functional area will include the following considerations:

Adequacy of administrative controls; Adequacy of supe visory review in the functional ares; Adequacy of training and qualificatica of personnel; Adequacy of documentation and records control systems; Overall effectiveness in conolying with NRC requirements; Attitude in assuring safe operations; and Significant performance deviations or trends noted from previous evaluations.

The' board's evaluation of the licensee's enforcement history in each functional area will include identified items of noncompliance and escalated enforcement actions.

A statistical analysis will not be perfomed on noncompliance data; but an indepth analysis of indicated trends and sanction points will be determined and will be considered in the evaluation.

The board's review of deficiency / event reports will consider the i

number, significance and repetitive nature of the non-routine even.ts or construction deficiencies in each functional area.

The board will provide an indepth analysis of these reports to identify adverse trends (causally-linked events) which indicate insufficient attention to the correction of the events or insufficient capabilities of licensee management in the functional areas.

This analysis is i

similar to that developed in the Trend Analysis Method described in SECY 78-554.

The NRR Project Manager will provide input on the licensee's l

perfomance in those functidnal areas in which he is knowledgeable.

i A manual chapter is being developed that specifies the functional areas to be evaluated and the methodology for performing the evalua-tions.

This evaluation differs from the Regional Survey Method performed by i.

the E4ys As'sociates (referenced in SECY 78-554) in that it is a structured evaluation which represents the consensus of regional personnel and is supportable by inspection results and event reports as opposed to the Hays questionnaire which contained anonymous l

unsupported opinions.

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b.

Evaluations b'y NRR I

NRR project managers and NRR technical support program personnel-will perform an evaluation of each power reactor licensee semiannually and will submit the evaluation to the SALP Review Group for inclusion in their review.

The details of this evaluation are yet to be

. developed.

In addition, the NRR QA Branch and selected contractors are developing acceptance criteria to describe the capabilities-(number of people, kinds of people, background, experience, training, etc.) required of licensee management. This program.is Task I.B.1 in NUREG-0660.

They will subsequently evaluate all ifcensees against these criteria.

4 Deficiencies identified in this study will be discussed with each licensee and will be documented in a report.

NRR plans to complete this effor+ in the spring of 1980.

The results of this one-time study will be provided to the SALP Review Group for their initial

. evaluations.

c.

Performance Appraisal Branch (PAB) Inspections 2

6 Management Appraisal (MA) Inspections will be performed by the PA8 on selected licensees in each Region.. The objectives of these 4

j inspections are to provide a national perspective of licensee performance; to identify performance traits that licensees may have j

in common; and to confirm inspector objectivity.

1 l

The MA ir.spections are conducted at the licensee's corporate offices

. and at the reactor site with emphasis on evaluating the effectiveness i

of the licensee's management in controlling licensed activities and j

in providing technical support to ensure compliance with regulatory requirements and safety of operations.

Results of these inspections l

will be furnished to the the SALP Review Group.

. The technique for appraising licensee management performance is discussed in detail in the PAB annual report for FY 79.

Basically, l

the MA inspection involves a'n appraisal of the licensee in a number of functional areas.

The appraisals in these functional areas are l

based on a mangement control system which should contain the foliovir.g features:

Written policies and procedures l

Adequai:y of the program to cover current requirerants and-guidance.

Qualification and training of personnel implementing the

(

program j

Awareness by the personnel implementing the program of their responsibilities J

+

_ Implementation of the program IE Program Appraisal (PA) Inspections will also be conducted.

These inspections are primarily designed to determine IE program effective-ness; however, information from these inspections will be provided to the SALP Review Group when the inspection results indicate a licensee performance problem er a significant program weakness.

Manual chapters are being developed specifying the methodologies of the MA and PA inspections and appraisals.

l l

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SALP REVIEW GROUP CHARTER 1.

Objectives The program for the Systematic Assessment of Licensee Performance (SALP) will evaluate the ability of power reactor licent-es to meet their regula-tory requirecents and to avoid significant events The SALP Program with modifications, may be applicable to major fuel facilities and major by product licensed facilities.

The primary objectives of the SALP Review Group are to identify unacceptable

. elements of licensee

• performance by reviewing licensee appraisals; to improve licenzee performance by recommending corrective action to the Director, IE and/or the Director, NRR; and to overview the consistent application of the SALP program throughout the regional offices.

2.

Responsibilities and Authorities The Review Group receives the evaluations and appraisals suus.ii.ted by the Regional offices, NRR, PAB, and any other related evaluations.

The Revie.s Group staff will do a preliminary assessment of the evaluations /

appraisals to assure that the documents are complete and that evaluations /

appraisals which identify significant problems are immediately distributM to each of the Review Group members.

If any of the members feel that the identified issues require immediate corrective action, tney will recommend to the Review Group Chairman that the Group meet immediately to review the issue.

For-those licensees that do not have issues requiring immediate action, the Review Group staff will assemble a package containing all appraisals and evaluations for that licensee in preparation for the Review Group's periodic review.

The review Group will generally review the appraisals / evaluations for all of the licensees in a given region as a unit.

The Review Group may visit a given site or Region or may request the presence of the appropriate Regional Director or staff to clarify any questions regarding the licensee's performance and the region's plans for corrective action.

Theappraisal/evaluationpackadeswillbedistributedtotheReviewGroup members prior to their meetirig to enable a timely review by the members before the packages are discussed in a meeting.

The Review Group will also evaluate the consistency of the appraisals from region to region.

The PAB inspection results will assist the review Group in calibrating or normalizing the regional appraisals.

• Appiicants in the case of power reactor under construction.

-1 3.

Composition-The Review Group shall consist of four members of senior NRC management appointed by the EDO.

The Chairman of the Review Group shall be a senior manager from OIE.

The three remaining positions shall be filled by a senior. manager from the Office of NRR, IE, and AE00.

A.

Use of Alternates Alternates will be. appointed in writing to perform the duties of a regular member in his absence; however, the alternate shall be a member of senior management and shall be given appropriate notifica-tion of this assignment.

B.

Consultants The Review Group may require the attendance of regional and headquarters personnel to provide clarification of issues under

{

discussion.

These personnel shall not be iur.luded in the final decision making process of the Review Group.

C.

Secretary A full time technical secretary will report to the Review Group Chairman and have the following responsibilities:

Maintain the Review Group records Arrange for Review Group meetings and site and region visits, as necest,ary.

Take and distribute meeting minutes.

Assist assigned technical staff in their activities i

Route SALP correspondence to Review Group members Prepare and distribute correspondence and other information, including review schedules, as directed by the Review Group 4

Chairman.

The secretary shall not take part in the decision making process of the Review Group.

This is intended to be a training rather than a i

permanent assignment; it is intended to provide needed assistance to the SALP Review Group and an opportunity to the assigned individual J

to receive on-the-job training in an impo" tant NRC program and to i

boraden his or her perspective of the Cona4ission's overall mission.

Since it is more an NRC than an individual Office program; individual Offices, on rotating bases, will be asked by the EDO to detail an appropriate GG-9 to 12 level individual to the Review Group Chairman i

1 for a period of about one year.

i l

D.

Review Group Staff The Review Group shall have an assigned staff of two experienced i

professionals, one from IE and the other detailed from NRR to IE.

i Both will report to the Review Group Chairman and will provide j

l-assistance to the Review Group including the preliminary screening f

~ - -

,:n

of the appraisols/evalusticns to d;termins if immediats rsview/tcticn is required by the Review Group.

It is intended that these full-time postions not be permanent assignments but that competent individuals be rotated into them for about an eighteen month period.

4.

Meeting Frequency The Review Group shall convene periodically as necessary to review regional appraisals.

Meeting frequency will be no less than every two months.

5.

Quorum A quorum shall consist of three (3) members including the Chairman.

No more than one alternate may be used to constitute a quorum.

Each member of the Review Group, including the Chairman, shall have equal responsi-bility and authority with regard to decisions of the Review Group.

A tie decision by the Review Group shall be reported as such to the appropriate Office Directors.

A dissenting member is free to express his position with regard to a Review Group decision or recommendation.

The dissenting opinion should be provided in writing as a supplement to the meeting i

minutes and should specify the reason for the member's dissent.

6.

Meeting Records Meeting minutes shall be taken and shall include the extent of the Review Group's concurrence with the appraisals and evaluations and the regiona'i

' action plans.

The Review Group's recommendations for additional or i

alternate action kill also be discussed when appropriate.

The meeting i

minutes will be distributed to the Director, IE; Director, NRR; and the applicable Regional Director.

i l

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U.S. NUCLE AR REGUL ATORY COMMIS$10N

,y BIBLIOGRAPHIC DATA SHEET NUREG-0834

4. TITLE AND SUBTITLE (Add Volume Net, s(apprepnew)

2. (Leave bir4/

NRC Lf:ensee Assessments

3. RECIPIENT'S ACCESSION NO.

5. DATC REPORT COMPLETED

. AufnORm D.G. Eisenhut, C. Michelson J. H.-Sniezek, N.C. Moseley (SALP Review Group)

, dug,ust y v.,q 981 y

9 PE RFORMING ORGANIZATION N AME AND M AILIN(e ADDaESS (include lip Code /

DATE REPORT ISSUED US Nuclear Hegulatory Commission uours lvaan Office of Inspection and Enforcement Auoust 10A1 Washington, DC 20555

s. (te.ve oi.nas

8. (Leave blank)

12. SPONSOHING ORGANIZATION N AME AND MAILING ADOFIESS (include lip Codel p

g US Nuclear Regulatory Commission si. CoNTR ACT NO.

Office of Inspection and Enforcement Washington, DC 20555 4

13 TYPE OF REPORT PE nsOD COVE PE D (Inclusive 5dArs)

Regulatory 1979-1980

14. (Leave o/m&/

15. SUPPLEMEN TARY NOTES I

16 ABSTH ACT d200 evords or kas/ '

This is the first report concerning NRC's program entitled Systematic Assessment of Licensee Performance (SALP).

It provides facility ratings for operating power reactor licensees and construction oermit holders as determined by the NRC's SALP Review Group. Facilities are rated is above average, average, or below average.

l-17 AE Y WORDS AND Dv;UMENT AN ALYSIS 17a OESCRIPTOR$

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21. NO OF P AGES 18 AV AIL ABILITY 4T ATEMENT g

20 SECUR6TY CL ASS f Th,s pap /

22 PRICE NIc r onu 3Js i? 771

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