ML20036C014
| ML20036C014 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1993 |
| From: | Remick NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9306080301 | |
| Download: ML20036C014 (3) | |
Text
- S'
.......................JI
~*
RELEASED TO THE PDR.
- E N 0 T ALT I'0 N VOTEt SP/cy5 d,
RESPONSE SHEET
[,,,,$$4,,,,,,,,((83,,,, '
T0:
SAMUEL J. CHILK, SECRETARY:OF THEiCOMMISSION-'
I FROM:-
COMMISSIONER REMICK
SUBJECT:
SECY-93-090 - SYSTEMATIC' ASSESSMENT OF-LICENSEE PERFORMANCE (SALP) PROGRAM 1,, W r., /* h APPROVED X DISAPPROVED -X ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION
-COMMENTS:
m U" ' A' 'I See 1
J/
(////
SIGNATURE RELEASE VOTE
/X/
/ I A /h / 9'3 DATE i
WITHHOLD VOTE
/
/
d ENTERED ON "AS" YES /
NO pp
- r 88ana 3R882" t
CORRESPONDENCE PDR
\\
commissioner Remick's comments on SECY-93-090 With one exception, I approve the proposed changes to the SALP Program and compliment the staff for the thoroughness of their review.
The exception is that I disapprove the continued use of numerical SALP performance ratings of licensees.
I do not think that the numerical ratings add any value to the positive attributes of the SALP process and there is ample evidence that the numbers can be misinterpreted and misused (e.g.,
economic-regulatory, and financial institution decisions based on averaging scores across the various SALP functional areas).
The most valuable attribute of the SALP Program is that it provides a disciplined process for meaningful dialogue with the licensee regarding its performance, a dialogue based on the insights gained from a structured synthesis of NRC observations and integrated assessments durino-an assessment period.
In short, the written evaluation of licensee performance and the oral dialogue with the licensee are the key attributes of this program.
At one time, the performance ratings used in the SALP Program were "above average," " average," and "below average."
- However, some individuals could not understand how the Commission could allow plants evaluated as "below average" to continue to operate.
The Commission solved the problem by assigning numbers to the ratings.
However, the use of numbers has resulted in other misunderstand 1ngs and misuses both by external entities and by some licensees.
'deally I would prefer not to assign any type of performance ratings to the four SALP functional areas, but instead emphasize and optimize the benefits of the written evaluation and oral dialogue aspects of the SALP process.
The agency now has'the Senior Management Meetings, in which SALP evaluations are used as an integral component, to identify problem plants and good performers.
Do we need two such overlapping performance rating systems?
I fear that some are not prepared to entirely eliminate performance ratings from the SALP Program.
Therefore, as a pragmatic alternative, I recommend that we discontinue the use of numerical performance ratings and utilize a more descriptive rating system, which is less likely to be misused.
The staff has provided us with an excellent and readily adaptable alternative-rating system in its draft rewrite of Management Directive (MD) 8.6, dated March 30, 1993.
On page 6 of MD 8.6, the staff has indicated "The three category ratings are as follows:
o Category 1.
Licensee attention and involvement have been properly focused on safety and resulted in a' superior level of performance.---
?>
o Category 2.
' Licensee attention and involvement are normally well focused and resulted in a good level of performance.---
o Category 3.
Licensee attention and involvement have resulted in an acceptable level of performance.-- "
r I recommend that we not use the-" Category 1, 2,'and=3" ratings, but instead use " Superior Performance," " Good Performance," and
" Acceptable Performance."
Such ratings are more descriptive than numbers and are self-consistent with the written text on'page 6' of MD 8.6 describing the performance ratings.
Some may assign their own numbers to the proposed performance ratings, but they would be doing so on their own without'the NRC's directly providing the ammunition to do so.
Further, in:
the explanation of the change, I recommend that we not say that the Category 1 performance rating has been changed to Superior Performance, etc.
Instead, we should indicate that we are, making several changes to the SALP Program, including the licensee performance rating system, and the new performance rating system is described on page 6 of MD 8.6.
.i J
j l
~
2
. - -