ML20044H402
| ML20044H402 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1993 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| REF-10CFR9.7 NUDOCS 9306080342 | |
| Download: ML20044H402 (7) | |
Text
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UNITED STATES g'ig
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,,e May 19, 1993 OFFICE OF THE SECRETARY MEMORANDUM FOR:
James M. Taylor q
Executive Director for Jp3 rations FROM:
Samuel J. Chilk, Secre 7
SUBJECT:
SECY-93-090 - SYSTEMA I ASSESSMENT OF LICENSEE PERFORMANCE S
P) PROGRAM The Commission has approved the staff's recommended changes to the SALP program and the implementation of Management Directive 8.6, subject to the changes discussed below and indicated in the attachment.
The staff should implement Management Directive 8.6 for assessment periods which end 60 days after the issuance of this SRM.
(EDO)
(SECY Suspense:
7/19/93)
The Commission (with all Commissioners agreeing) has agreed with the staff's recommendation to delete the Safety Assessment / Quality Verification (SA/QV) functional area, with the understanding that the issues that were previously addressed in this functional area will now be addressed as an integral part of the four functional areas recommended by the staff.
In addition, the Commission believes that in view of the importance of the issues previously addressed in the SA/QV functional area, particularly the self-identification of a licensee's problems, the cover letter forwarding a licensee's SALP should include a brief discussion of how effective the Regional Administrator believes a licensee is in discovering its own problems and correcting those problems.
While agreeing with this approach, Commissioner de Planque would have preferred to not limit the staff to addressing this in the cover letter, but instead would allow the staff the discretion to determine how this can best be done.
The Commission (with the Chairman and Commissioners Rogers and Curtiss agreeing) has agreed to retain the use of trend SECY NOTE:
SECY-93-090 WAS RELEASED TO THE PUBLIC ON APRIL 15, 1993.
THIS SRM AND THE VOTE SHEETS OF ALL COMMISSIONERS WILL BE MADE PUBLICLY AVAILABLE 10 WORKING DAYS FROM THE DATE OF THIS SRM ib 9306080342 930519 Vfh' PDR 10CFR PT9.7 ppa 1k
- information in the SALP process, as follows:
The information indicated in the attachment should be added to the Handbook.
The staff should provide the trend information in the report but not attach it to the numerical scores.
Commissioners Remick and de Planque would have preferred to delete the performance trends.
The Commission (with the Chairman and Commissioners Rogers and 1
Curtiss agreeing) has agreed to retain the numerical scores used in evaluating licensees.
Commissioners Remick and de-Plangue would have preferred to delete the numerical scores.
Their additional views are attached.
With regard to focusing on the adequacy of utility resources (i.e.,
staffing levels, level of financial resources) in the SALP process, the commission recognizes that there may be occasions when the SALP Board needs to address the adequacy of utility resources.
In the Commission's view, however, this should be limited to cases where -- (i) specific performance problems are evident, (ii) licensee management does not appear to recognize that limited resources are directly contributing to the performance problem, and (iii) focusing on the adequacy of resources is the only course of action available to the staff to address the issue in an effective way.
The Commission woulo expect that the frequency of such cases would be rare.
If such cases arise, the nexus between the performance problem and the adequacy of resources must be firmly established.
Finally, the staff should ensure that those individuals involved in the SALP process understand that the focus of the SALP process is to assess licensee safety performance, not to recommend or impose solutions.
Attachments:
As stated cc:
The Chairman Commissioner Rogers Commissioner Curtiss Commissioner Remick Commissioner de Planque OGC OIG Office Directors, Regions, ACRS, ACNW (via E-Mail)
ASLBP (via FAX)
Additional Views of Commissioners Remick and de Plangue l
Commissioners Remick and de Planque do not think the numerical ratings add any value to the positive attributes of the SALP process, which are principally the written evaluation of licensee safety performance and the oral dialogue with the licensee.
SALP scores, and their impact on a licensee, are clearly powerful tools that have greatly influenced (or as some have put it, dominated) licensee performance and use of resources, as noted in the Regulatory Impact Survey.
There is ample evidence that the numbers can be misinterpreted and misused by a variety of parties.
The proposed changes may reduce, but will not eliminate, such misuses.
Also, the use of three levels of scores to assess the degree to which licensee performance exceeds an acceptable level has led to concerns on the part of ACRS and others about undisciplined ever-rising performance expectations.
Therefore, we remain unconvinced that there is an overriding need to retain numerical scores especially in view of the misinterpretation and misuse of the scores.
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Volume 8, Licensee Oversight Programs Systematic Assessment of Licensee Performance (SALP).
Handbook 8.6 Part I i
Performance Category Ratings (o)(continued) i The final rating for each functional area will be a composite rating of the performance based on a knowledgeable balancing of the issues in a j
functional area and their safety significance. (2)
The three category ratings are as follows:(3)
Category 1. Licensee attention and involvement have been properly focused on safety and resulted in a superior level of.
performance. Licensee programs and procedures have provided effective controls.The licensee's self-assessment efforts have been l
E usccin the identification of emergent issues. Corrective l
effet +ive.
d actions are technically sound, comprehensive, and thorough.
Repeat problems are eliminated and resolution ofissues is timely.
-l Root cause analyses are thorough. Licensee resources 'are effectively applied. (a)
Category 2. Licensee attention and involvement are normally well focused and resulted in a good level of performance. Licensee 1
progra ms and procedures normally provide the necessary control of acuvities, but -deficiencies may exist. The - licensee's self assessments are normally good, although issues may escape-identification. Corrective actions are usually effective, although some may not be complete. Root cause analyses are normally thorough. Licensee staffing and resources are generally effective.
but at times. may be strained. (b)
Category 3. Licensee attention and involvement have resulted in an acceptable level of performance. However, licensee 7
performance may exhibit one or more of the following I
characteristics. Licensee programs and procedures have not prosided sufficient control of actisities in important areas. The licensee's self-assessment efforts may not occur until after a potential problem becomes apparent. A clear understanding of the safety implications of significant issues may not have been demonstrated. Numerous minor issues combine to indicate that l
the licensee's' corrective. action is not thorough. Root. cause.
analyses do not probe deep enough, resulting in the incomplete resolution ofissues. Licensee resources are restricted, limiting the effectiveness of programmatic and/or corrective action. Because i
the margin to unacceptable performance in important aspects is small, increased NRC and licensee attention is required. (c)
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6 Approved: (Draft March 30,1993)
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. Volume 8 Licensee Oversight Programs Systematic Assessment of Licensee Performance (SALP)-
Handbook 8.6 Part 11 i
Assessment Process (A)(continued) l Completion and Issuance of the SALP Report (3)(continued).
report will dictate the length of the report. The SALP cover letter-should include the following:
A characterization of overall safety performance of the licensee.
The SALP cover letter will highlight common themes oflicensee performance identified by the SALP process. The cover letter should characterize the licensee's performance and should place in perspective any significant events or_ findings that.took place i
outside the assessment period that bear on the evaluations in the report. The SALP report should be consistent with the results of any other current events and processes related to the plant's performance, such as results of. recent Senior-Management-Meetings and major team inspections, to ensure that conflicting.
messages are not inadvertently transmitted to the licensee. (a)
Areas or issues that warrant discussion during the meeting with the licensee. For any functional area rated Category 3. the cover letter The cover letter will should request that the licensee be prepared. to discuss include a specific performance and planned actions in this functional area. (b) reference to and assessment of the licensee's safety For all functional areas rated Category 3, the cover letter will Assessment / Quality request the licensee to reply in writing within 30 days and proside verification activities, planned corrective actions to improve performance. (c)
The cover letter and functional area-assessments will be transmitted to the licensee before being publicly released. (d)
Copies of the report should be provided to the offices of th'e EDOi the Director. NRR: the Director. Office of Enforcement: the Commissioners: and the NRR Disision of Reactor Inspection and Licensee Performance (DRIL) SALP Program Manager. The SALP report will be distributed on a timely basis as a standard docket item to the Document Control System. the NRC Public Document Room. the appropriate Iwcal Public Document Room.
and the Institute of Nuclear Power Operations. Each report will oe assigned an inspection report number. (e)
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Appmved: (Dratt March 30.1993) 11 --
B Volume 8, Licensee Oversight Programs Systematic Assessment of Licensee Performance (SALP)
Ilandbook 8.6 Part II t
SALP Meeting With the Licensee (s)
General (1) nosoonerihm-The SALP meeting with the licensee should be scheduledg! !:a= 2 weeks after the SALP report has been issued. Additionally, this public meeting with the licensee's management will be held within 60 days of the end of the assessment period to discuss the assessment. The.
meeting will be conducted on site or in the vicinity of the site, if.
feasible. to foster accessibility and a more widespread understanding -
i of the NRC'sviews.~n'e regie"2! ad ";" rater.ay decide r~ te ^!da h
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rector, M wW:~be informd in wmmg when a -
dministrator will
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ormally hold a SALP ublic meeting unless SALP public meeting is not held.
nusual circumstances rise which may make a Meeting Preparation (2) ublic meeting nnocessary or The region shall notify those on distribution for the SALP report of the nadvisable.
meeting with the licensee. (Set. 5.. tion (B) of this part.) (a)
'l The region shall notify the media and State and local government officials of the issuance of the SALP report and of the meeting with the licensee once the report has been released. Generally, at least I week's i
notice should be provided before the meeting. (b)
The licensee should be encouraged to have the following management representatives participate in the meeting: (c)
The senior corporate nuclear officer / manager (i) e Management officials responsible for the major functional e
areas (ii)
The site manager (iii) l Licensee Meeting (3) i The regional administrator will designate the NRC participants for the licensee meeting. NRC participants for this meeting typically include the following: (a) 12 Approved: (Dratt March 30.1993) l
i Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part I s
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Performance Trend (n)
NRC should examine licensee performance during the assessment period to determine whether a trend exists. Of particular interest are those licensees with a Category 3 performance rating and a declining trend. If senior NRC management has not been previouslyinformed.
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these situations should be brought to the attention of the Director, hJ NRR; the Deputy Executive Director for Nuclear Reactor j[
Regulation, Regional Operations, and Research; and the regional e
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administrator. (1) g k
P The performance trend should be determined selectively and should 10.(d i
p be reserved for those instances in which it is necessary to focus the gs attention of NRC and the licensee on an area with a declining b
f performance trend, or to acknowledge an improving trend in licensee
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o performance. (2) j The trend,if used, may be de6ned as either improving or declining:(3) s improving. License e performance was determined to be improving e
during the assessment period and contmuation of the trend may result in a future change in category rating. (a)
. Declining. Licensee performance was determined to be declining during the assessment period and continuation of the trend may result in a future change in category rating. (b) o
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