ML20034B653

NRR Ofc Ltr 907,Rev 1 Submitting Procedures for Providing Input to SALP Program

ML20034B653
Person / Time
Issue date:	04/18/1990
From:	Murley T Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NRRL-907, NUDOCS 9004300138
Download: ML20034B653 (11)

Text

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(d UNITED STATES

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g NUCLEAR REGULATORY COMMISSION 5

5 WASHINGTON, D. C. 20666 9.....

April.18,1990 MEMORANDUM FOR: All NRR Employees FROM:

Thomas E. Murley, Director Office of huclear Reactor Regulation

SUBJECT:

NRR OFFICE LETTER NO. 907 REVISION-1 NRR PARTICIPATION'1N THE SALP PROCESS PURP0SE This revised office letter presents the Office of. Nuclear Reactor' Regulation (hRR) procedures for providing input to the sysimatic assessment of licensee performance (SALP) program - and defines the : NRR responsibilities outlined in NRC Manual Chapter 0516. " Systematic Assessment of Licensee Perfor: nance." This office letter does not supersede the manual-chapter or repeat all information contained therein.

Employees should refer to NRC Manual Chapter 0516 for detailed information.

This revision reflects recentLchanges in the process for.

integration of SALP inputs within NRR and supersedes NRR Office Letter No. 907, dated October 6, 1988.

BACKGROUND 1

The SALP process is an integrated agency effort to. collect and evaluate av611able insights, data, and other information on a plant / site basis in a structured manner in order to assess and.better understand a licensee's performance.

SALP is used to integrate licensee performance 'information to focus attention on areas of concern and on licensee. management effectiveness, including strengths and weaknesses. within each functional area and across functional areas.

NRC intends that the SALP process further-its understand-ing of how licensee management guides, directs, and provides. resources for ensuring plant safety.

NRC expects to provide meaningful feedback to licensee-i management and to provide a basis for allocating NRC resources.

RESPONSIBILITIES AND AUTHOR 1 TIES The Director. NRR, implements the requirements of this office letter and the associated manual chapter within NRR, monitors the SALP process, evaluates and develops SALP policy, criteria, and methodology, and assesses the uniformity and adequacy of the implementation of the program.

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1 R. Nease, DLPQ, LPEB, NRR 492-1029 p

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-l All WRR Employees

-2 Ap.'il 18,1990 l

The Associate Director for Projects ensures NRR-participation in the SALP board, and that 5 ALP inputs are properly integrated and are provided to. the regional SALP board on the established schedule.

The Associate Director for Inspection and Technical Assessment (ADT) ensures that individual inputs-to the 5 ALP from the technic 61 staff address licensee performance, and are provided to the appropriate NRR Project Director -in a timely manner.

The Assistant Director. Projects.

coordinates with the - regional projects l

division any special arrangements for responsibilities of specific functional i

areas.

The NRR Project Director participates in each SALP review as a voting member of the 5 ALP board for plants in his or'her directorate.

i The Performance and Quality Evaluation Branch (LPEB) provides oversight of the SALP program and its implementation within NRR and by the-regions. ' The LPEB also coordinates with the ADT ttaff the scheduling of inputs, and reviews ADT inputs provided to the appropriate NRR Project Director.

The NRR Project Manager coordinates NRR' inputs to the SALP.

The NRR project manager also coardthetes with the regional staff in preparing a draft of the SALP report for consideration and discussion by the SALP board and participates in the SALP board as a voting member.

The NRR Technical Staff in the Divisions of Engineering Technology, Systems Technology, Opt: rational Events Assessment, Radiation Protec. tion and Emergency l

Preparedness, Reactor Inspection and Safeguards, and Licensee Performance and Quality Evaluation provioe assessments of the adequacy, as well as the i

strengths and weaknesses, of licensee activities as input to the NRR integrated j

SALP input.

l BASIC REQUIREMENTS i

NRR SALP INPUTS Manual Chapter 0516 lists eight functional areas for operating plants:

t Plant Operations Radiological Controls Maintenance / Surveillance 4

4 Emergency Preparedness Security Engineering / Technical Support Safety Assessment / Quality verification Other The SALP input' provided by NRR will address one or more of these functional areas, as applicable.

- All NRR Employees April 18, U90 A SALP input from each organization responsible for seveloping a safety evt uation report (SER) will routinely accompany each SER input.

The SALP inputs will be supplied as an enclosure to the memorandum forwarding the SER input to the appropriate division of reactor projects with a copy marked LPEB.

SALP inputs shall also be provided on NRR interactions with. licensees that do not necessarily result in SER inputs.

- That is, a SALP input should be provided that assesses licensee perforinance as a function of insights gained during on-site inspections, program reviews related to significant technical or safety issues, significant interactions _ with the licensee during meetings, etc.

Such a SALP input should be provided 2 weeks after the end of the inter-action or 4 weeks before the end of the SALP assessment period. This input should be sent to the = project director, unoer signature of. the - reviewer /

inspector's branch chief, with copies to the appropriate assistant or deputy division airector end LPEB.

Ex6mples of inputs that should be provided are assessments of licensee responses to reportable events from the Events Assess--

4 ment Branch, assessments based on examinations from the Operator Licensing Branch, ano insights from any NRR' team inspections.

LPEB is responsible for ensuring that schedules for such required SALP inputs - are ;provided to us technical staff ano to the responsible project director, and that they are

. I updated as needed.

Enclosure I provides the format for individual NRR inputs;to SALP.

Note that numerical ratings are not to be provided.

Rather, a narrative discussion that lends itself to evaluaIT6n by the attributes specified for each of the evalua-tion criteria should be provided.

Specific details or examples underlying the I

incividual's perccption of that performance are casirable.

Individual hRR SALP input will generally fall within either the functionc1 areas of Safety -

Assessment /Qua lity Verification or Engineering / Technical Support.

Other functional areas shoulo be addressed to the extent appropriate information is available.

Guidance on preparution of SALP input, including examples, is proviced in Enclosure 2.

Inputs receiveo from the various technical divisions will be reviewed' on 6 sampling basis by LPEB to ensure that ADT SALP inputs are prepared-in accord-ance with this office letter.

The NRR project manager shall combine the input received from ADT with his or her own assessment of licensee performance including input from management in the appropriate division of reactor projects. :This product shall be forwarded to the SALP board chairman by the input due date under signature of the NRR project manager through the project director with assistant director concur-rence. A copy shall also be sent to LPEB.

The NRR project manager shall work directly with desigM.ted regional staff to 1

prepare the draft SALP report for presentation to the SALP board.

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All NRR Employees Aprii 18,1990 i

i PARTICIPATION ON SALP BOARDS NRR representation at SALP board and licensee sanagement meetings will be as follows:

(1) The appropriate project director and the' project manager are SALP Board members and are expected to attend both board and management meetings.

.i (2)- Prior to participating in the SALP board meeting, the Project Director i

and Project. Manager shall be familiar with the current revision of Manual Chapter 0516.

EFFECTIVE DATE This revised of fice letter is effective insiediately.

W, Thomas E.- Murley, ofrector Office of Nuclear Reactor Regulation l

Enclosures:

l 1.

Format for SALP input t

2.

Examples of hRR SALP input w/ Figure I cc:

J. Taylor, EDO J. Snfezek, DEDR E. Jordan, AE00 l

T. Martin, RI S. Ebneter, Ril A. Davis, Rill R. Martin, RIV J. Martin, RV SECY OGC NRC PDR

' ' All NRR Employees 4

April 18, 1990 PARTICIPATION ON SALP BOARDS NRR representation at SALP board and licensee management meetings will be as follows:-

i l'

(1) The appropriate project director and the project manager are SALP Board members and are expected to attend both board and management meetings.

(2) Prior to participating in the SALP board meeting, the Project Director and Project Manager shall be familiar with the current revision of Manual Chapter 0516.

_E_FFECTIVE DATE This revised office letter is effective immWt%9.hcigaeo by-nemm E. Furle ThoCas E. Murley,yDirector Office of Nuclear Reactor Regulation

Enclosures:

1.

Format for SALP Input i

2.

Examples of NRR SALP input w/ Figure 1 cc:

J. Taylor, EDO T. Martin, RI R. Martin, RIV OGC J. Sniezek, DEDR S. Ebneter, RII J. Martin, RV NRC PDR E. Jordan, AE0D A. Davis, RI!!

SECY DISTRIBUTION: p s

• Central F11e4 W ATGody MCaruso RNease-PQEB Reading C0 Thomas WBateman FHawkins Document Name:

907

' Changes minor; Tech. Editor's concurrence not required because the changes relate to branch and other organizational changes. HS

• See previous concurrence sheet 3

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NRR:DLPQ:PQEB NRR:DLPQ:PQEB :hRR:DLPQ:DQEB : TECH EDITOR

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• RNease:

• MCaruso

• ATGody

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• C0 Thomas

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DATE

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3/16/90

3/16/90 m

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NRR:ADP-NAME

• HSmith

• VWilson

• JLarkins

• FGillespie

• WTRussell1

JPartlok DATE :3/28/90

3/29/90

3/29/90

3/30/90

4/2/90

4/l3/90 0FC

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iNAME :Tiurley

^DATE :4//Y390 0FFICIAL RECORD COPY

FORMAT FOR SALP 1NPUT FACILITY WAME

SUMMARY

OF REVIEW /INSPECTIDH ACTIVITIES.

[Briefly describe the review / inspection activities conducted, including the topic of the review / inspection, the organizational unit (s) that conducted the review / inspection, and the applicable date/ time frame.

Develop the major-conclusions from the effort and discuss impact of the findings.]

t NARRATIVE DISCUS $10N OF LICENSEE PERFORMANCE - [ FUNCTIONAL AREA]

[ Characterize licensee performance in lig]ht of the evaluation criteria prov in Appendix A of NRC Manual Chapter'0516.

i AUTHOR:

DATE:

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WRR INPUT INTO THE SAtP PROCESS Figure I shows the various sources of data 1nput for the integration process.

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Before writing input, review the SALP Manual Chapter,. concentrating -on the evaluation criteria and the attributes associated with each of these criteria.

In order to convey key thoughts, technical staff must' think the issues through and document the results effectively.

]s 1.

WHY IS GOOD SALP INPUT NECESSARY?

to facilitate accurate conclusions by the SALP board to effectively communicate to the licensee NRC's perception' of-strengths and weaknesses to analyze proper allocation of NRC resources to ensure that accurate information is presented to the licensee at the public management meeting 2.

INPUT TO THE SALP PROCESS l

should be categorized by. functional area must not be given a numerical rating;- the SALP board is respcnsible i

for assigning numerical ratings must not be superficial or inflamatory must be accurate, concise,'and substantial-must be timely should leno itself to being diagnoseo on a larger scale when combined with other inputs should not overuse the phrases stated in 'the attributes for the evaluation criteria should meaningfully coment on a licensee's performance, both positive and negative 3.

EXAMPLES l

Least helpful:

(functional area -is not obvious) a.

Review of SER

, did not identify - any concerns (Category 2),

b.

The licensee's meeting to discuss the completion status of Bulletins l

79-02 and 79-14 appeared to address NRC concerns.

The licensee dic not make a comitment to complete its effort (Category 3).

c.

Best licensee program of receipt inspection I've ever seen (Category 1).

d.

Performed inspection of,

with no findings (Category 2).

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j The above exaeples are poor in that they do not offer much information that can be used to evaluate a licensee's performance. Also, they present a reting, and the rating is the responsibility of the SALP board.

Review the evaluation i

criteria and associated attributes, being aware of each' staff member's role in support of the SALP board, and develop input that will result in.a-SALP rating-that is meaningful;, that is, the input will, help NRC _ and the licensee know what, if any, action should be taken.-

Helpful: ENGINEERING / TECHNICAL SUPPORT' 1

a.

Review of SER indicated the licensee was - thorough' in its approach to addressing the various technical aspects of the issue.

The issue was difficult. -yet the licensee's technical expertise was sufficient to. satisfactorily resolve all possible questions.

b.

The licensee-requested ' meeting to discuss the completion status of Eulletins 79-02 and 79-14 ~was a worthwhile - initiative.

However, the information-presented was technically weak and indicatea no significant progress towards completion.

These twu examples give a feeling for the licensee's performance.

_They contain more information and. address strengths and weaknesses.-

More Helpful: ENGINEERING / TECHNICAL SUPPORT a.

SER involved a complicated technical issue that overlapped

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into operations, - radiological

controls, and maintenance /

surveillance.

The licensee adequately ' addressed all aspects of the issue. This achievement indicated good interdepartmental communications, a technically qualified' staff, and responsive-ness to NRC issues.- In addition,- the licensee was very sensi-tive to the safety significance placed on the issues, i

b.

The licensee's licensing group is aggressive in pursuing safety issues.

However, in the case of a meeting to discuss 79-02 and 79-14, the licensee was inadequately prepareBulletins d for the meeting.

This situation has occurred in the past and indicates-an internal inconsistency in the ability of-various departments-to effectively communicate-and also indicates weaknesses in l

certain technical disciplines within corporate engineering-support.-

'These two examples describe the strength or weakness of the licensee's performance and the basis; for it.

The writer identified the strength or weakness curing his or her encounter with the licensee and pursued it until the basis for it was identified.

Note that in the second example one might i

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.,3 question in which functional area this discussion belongs.

Often the functional area is not readily apparent.

In this case, part of the information could -be' discussed. under Safety Assessment / Quality. Verificationc as well as :

Engtheering/ Technical Support.

Use your judgment and do not be reluctant to-repeat your comments in acre than one functional area, if appropriate.

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SALP INPUT PROCESS l

1 Resident Inspections __,

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' Region Based' Inspectionsk j

Tearn Inspections (HQ and Region) l Safety Evaluations i.

SALP we Board

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i NRC/ Licensee Meetings #

ray.e to Board Meeting 6

Members l

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Prograzn Reviews 31 Operator Licensing l

Examiners NRC/ Licensee.

Phone Contacts-o i

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' Interfaces I

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PARTICIPA710N ON SALP BOARDS.

L Presentation at SALP board-and licensee management meetings will be as (1) The appropriate project director and the project manager are SALP Boe.-d members and are expected to attend both board and management meetings.

t (2) Prior to. participating in the SALP. board meeting. the Project Director and Project Manager shall be familiar with the current revision of Manual Chapter 0516.

I EFFECTIVE DATE This revised office letter is effective inunq4htsheignedby.

Thomas E. Murle. ley, Director-

- adom E. Eur y,

Office of Nuclear Reactor Regulation

Enclosures:

I.

Formet for SALP Input 2.

Exansples of NRR' SALP Input w/ Figure I l

cc:

J. Taylor, EDO T. Martin, RI R. Martin ~ RIV OGC' l

J. Sniezek, DEDR S. Ebneter, RIl J. Martin, RV NRC PDR E. Jordan, AEOD A. Davis, RIII SECY i

DISTRIBUTION:

i Central File JWRoe ATGody MCaruso RNease.

l PQEB Reading COThomas WBateman FHawkins Document Name: 907 i

' Changes minor; Tech.Ed' tor's concurrence not required because - the changes relate to branch and other organizational changes. HS t

t

• See previous concurrence sheet i

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2/9/90

3/8/90

3/ /90

3/16/90

3/16/90-I.

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3/29/90

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3/30/90

4/2/90'

4/13/90 0FC

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-NAME :Tiurley DATE

4/

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