ML20058K188
| ML20058K188 | |
| Person / Time | |
|---|---|
| Issue date: | 05/25/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-PII, TASK-SE SECY-90-189, NUDOCS 9005310502 | |
| Download: ML20058K188 (80) | |
Text
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POLICY ISSUE May 25, 1990 (Notation Vote) sECv-90-189 g:
The Comissioners From:
James M. Taylor
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Executive Director for Operations
Subject:
REEVALUATION OF THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) PROGRAM
~ ~s~e:
To inform the Comission of the results of a staff reevalua-Pur tion of the Systen.atic Assessment of Licensee Performance (SALP)progrcm.
Sumary:
The SALP program is an integrated Agency ef fort to collect and evaluate av611able Agency insights, data, and other inforem-
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tion on a plant or site basis in a structured manner in order to assess and better understand the reasons for a licensee's performance.
Recent ccments, questions, and recomendations received from the Comission, the Advisory Coomattee on Reactor Safeguards (ACRS), the Inspector General, the NRC staff, and various utilities- (in the form of f eedback f rom the Regulatory impact Survey completed in March 1990) indicated that a reevaluation of the SALP progrcm was warranted.
A reevaluation was per-formed from January through April 1990 and resulted in the identification-and resolstion of seversi issues and subse-quent development of a ievision to NRC Manual Chapter (MC) 0516, " System 6 tic Assessmtnt of Licensee Performance."
The staff proposals for resolving the idthtified issues are reflected in the enclosed revision to MC 0516.
The revision addresses (1) numerical ratings of licensee performance, (2) performance category definitions, (3) a fourth performance category to address unacceptable licensee performance, (4) the SALP evaluation cycle, (5) suspension of SALPs under special circumstances, (6) the concept of rising performance standards and expectations, (7).the evaluation criterion " Responsiveness to NRC Initiatives," and (8) the responsibilities of regional administrators regarding the SALP program.
Contact:
G. Grant, NRR NOTE:
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Background:
The SALP program is an integrated NRC' staff-effort to:consoli-1 3
date available.information to support a. periodic evaluation ofL a licensee's overall performance.
The orogram has as its-L objectives -(1) the improvement of the NRC regulatory program'
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by. focusing NRC management _ attention-on-6 teas of' concern,-(2)
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the, improvement of licensee performance through dialogue
- between NRC senior management and licensees = directed toward problem areas, (3) the establishment of a mechanism for.-
focusing attention on the overall effectiveness'-
of.'a licensee's-management, and (4) the : support of 1NRC a.anagement in ' determining inspection'. resource allocations.:
The program has. matured over the.past 10 years and -has been,
revised in response to lessons learned regarding assessments of licensee performance.
The last major. revision to the SALP program was made-1'n June 1988.
Significant program changes ride in that revision included changing the length of-the evaluation period,: chang ;
ing the. number cf functional areas assessed-and. expanding i
their coverage, adding human ' performance attributes to Lthe e
evaluation - criteria, redefining _ = the performance. categories, and establishing a requirement for a formal meeting with licensee-management to discuss the SALP report.
A subsequent minor revision'was implemented in August-1989.
Program revisions included changes to the SALP report format, clarifi-cation of performance trends to cover the entire assessment period, and a change in the SALP report issuance schedule.
Af ter the June 1988 revision, questions arose from a number of diverse sources concerning catails of the SALP.; program.
The identified issues of concern included ' the performance category _ definitions, the numerical performance rating system -
the= number and types of performance categories, evaluation criteria, eno the internal (NRC) and external uses of the SALP.
Consideration of these bne other issues indicated that a review of the existing process was warranted.
The issues were adoressed in en assessment of the SALP program.
The.
assessment process and results are discussed below.
Discussion:
The reevaluation process encompassed several phases.
The first phase included a preliminary review of existing concerns and recomendations.
The second phase generated additional Issues through interviews of staff and senior managers.
The third phase consolidated the issues and solicited comments-on proposed resolutions.
The fourth phase finalized the resolu-tion of the issues and developed a revision to MC 0516.
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y reevaluation' spanned the months;of January through April:1990.
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and included the following steps:'
Staff review of concerns "and recomunendations regarding
.l the SALP process.
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' Discussion-and review.of! these concerns. and recommenda-tions at the January 1990 Senior Maragement-; Meeting.
A. meeting with professional ' staff who were; formerly senior resident inspectors to elicit their views on. the implementa' ion of the current SALP program, 1.,
-Interviews of all regional' administrators and several-1 i :'
_deputyt regional administrators to identify issues and i
discub's' solutions.
t Interviews of senior NRR managers to identify issues and 1
discuss. solutions.
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A joint.NRR/ regional-division director meeting to discuss B
potential changes to the.SALP program.
Review of the Regulatory impact survey.
Consolidation and review of the results of the above steps.
Development of a revised MC 0016.
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The major' issues developed by this p(rocess ' included 2) the use of t licensee perform 6nce rating process, performance ratings, (3) the number and types of performance categories, (4) performance category definitions, (5) the SALP.
assessment periodicity, (6) the: concept of rising performance standards 'and expectations, (7) the responsibilities of regional administrators regarding the SALP program, :(8) the evaluation-criterion " Responsiveness to NRC Initiatives," (9) 1 L
the composition of the SALP L.,ard, and (10) the SALP' report.-
The culmination. of this process was: the resolution of these issues and the development of a proposed revision-to NC 0516
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-(enclosed).
The issues and associated resolutions are
' discussed below.
L Licensee Performance Rating The SALP process is-used by the.NRC to synthesize its observa-tions of and insights into a licensee's performance and to icentify common themes or trends.
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strengths as-well'as weaknesses.
The SALP process is a means lV of expressing NRC senior management's observations and' judg-ments on licensee performance.' The; process'is-not limited to-i u
weaknesses,.and it is not intended to identify. proposed.
7 resolutions or; solutions to problems. The SALP ' process. is -
intended to' further NRC's understanding of (1) the way in which the. licensee's management' guides,idirects, evaluates, t
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'and provides resources for safe plant' operations, and (2) the:
1 effectiveness of these actions.- While the underlying causes of licensee events - trips or actuations-are reviewed during.
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'Y the SALP evaluation process, performance indicator data is.
not used as a factor in judgements about the effectiveness or sf' rating 11n a particular SALP functional area..
Current SALP 1
y' program guidance indicates that. it is inappropriate to m*ke reference to perfornience indicator program results in arriving at SALP ratings.
As a result, emphasis is placed on under-g' standing the reasons for 6 licensee's performance and on sharing. this understanding with the licensee. and the public.
The SALP process is intended to provide meaningful feedback-to a licensee's management and to be sufficie,ntly diagnostic to provide a-rationale for allocating NRC resources.
Currently, licensees are assigned a numerical performance rating in each of seven functional are6s for an operating phase reactor or nine functional areas for a construction phase reactor.
A functional are&: represents a grouping of similar licensee activities.
- Although not ~ all functional-areas need to be assessed in a given review, an explanation is given in the.SALP report if a f~unctional area that pertains to a licensee is not evaluated. The current functional areas for j
an; operating phase reactor are:
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Plant Operations Radiological Controis-l~
Maintenance and Surveillance Emergency Preporedness Security Engineering and Technical Support.
a Safety Assessment and Quality Verification r
The current rtumerical rating system ranges from Category 1, representing the highest level of performance, to Category 3, representing the icwest level of acceptable performance. The numerical rating of a functional area is occasionally modified by assignment of a trend (improving or declining).
- Normally, this performance trend is used if both a definite trend is discernable ar.d continuation of the trend may result in a change in performance rating.
The performance trend is I
intended to predict licensee performance during the next assessment period and is used in allocating NRC resources, i
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Severa1Eissues related to performance ratings were identifiedi 4-during this reevaluation, including the -numerical rating system,r the number and types of perform 6nce categories s and the performance category definitions.-
Each is discussed below..
Numerical Performance Ratings
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The staff reviewed-the practice of using numerical ratings in assessing licensee performance.
The staff found that the practice is well established and conforms to accepted methods of comununicating-performance.
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f' assessments. Numerical ratings f acilitate the communica-tion of consistent, identifiable, and definable assess-ments to a licensee.
Comparison of ' performances or improvements across SALP cycles is simplified and-promoted through the use of a graded system. The themes contained in the SALP report text are sometimes received:
or interpreted differently by various ' organizations.
Under current practice, numerical. ratings-define the tenor of the assessment.
Removal of the ratings might decrease the likelihood of accurately communicating the results of : the-assessment to the licensee.
A lack of 3' '
numerical ratings would probably necessitate detailed explanation and discussion with a licensee subsequent to issuance of the report in order to ensure the-assessment' wos adequately -communicated.
Additionally, numerical ratings simplify the use of the SALP program to assist in decisions on allocation of NRC resources. -a stated' SALP program objective, and permit easily retrievable histori-cal recorcs of performance.
The Commission expressed a desire for the staff to review
.the impact on the assessment process of the suspensich-of.
numerical ratings.
The staff believes the only benefit-of suspending the numerical ratings would be the possible cecrease in uses of SALP for whic1 it was never intended.
In light of the above, the staff proposes that the current practice of using numerical ratings be retained.
The staff review of the SALP process also indicated that sufficient definition and guidance exist on the intended uses. of SALP assessment data.
However, it is evident that SALP results are used by other organizations in ways not intended by the NRC.
This issue will be included as part of the ongoing staff review cf the uses by external org6nizations of NRC-generated data or information.
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The Commissioners 2.
performance Category Definitions i
L The. current performance-category ' definitions specify the attributes associated' with three levels-of. acceptable licensee performance.
The definitions address: licensee management attention.and involvement in nuclear safety or e
safeguards activities, the degree to - which regulatory requirements are met or are exceeded, the adequacy and l
allocation of. licensee resources., and the general level i
of future NRC. resources to be allocated.
Although ~ the definitions have been revised during the.
- history of the SALP: program, staff review indicated that further improvement was needed.
The revised. definitions in the enclosed MC 0516 revision are intended to simplify L
the category distinctions and: base the ratings on' l
observed licensee performance. The emphasis is placed on performance results and the level of future NRC sctivity L
in response to licensee performance.
References -to regulatory requirements and licensee resources have been celeted.
3.
BLmber and Types of Performance Categories Along 'with the review of category definitions noted above, the number and types of-performance categories l-were also reviewed.
Options studied included expansion of the current three-level system to a five-level system, and addition of a
new category for unacceptable L
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performance.
The staff concluded that the current three-category system was sufficient with the addition of a. fourth category for unacceptable performance.
The current-practice of selective-use' of a trend associated with. a i
l category rating (such as " Category.- 2, improving") was' l>
l retained in order.to allow for the appropriate K
differentiation of~ licensee performance.
1 The addition of a ~ fourth category for unacceptable performance ~ allows for the programmatic identification of.
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significant licensee problems.
It is anticipated that 1
assignment of an unacceptable rating would be primarily for historical purposes to document significant licensee problems that would be expected to be icentified by other events or assessment programs-.
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The addition of a "N"' category is primarily for admin-istrative purposes and identifies those cases..where-
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sufficient information was-unavailable to assess' licensee perfors.ance.
These cases-. would include instances in J
which a rating could not.be. developed because of. insuf-5 ficient licensee activity or insufficient NRC inspection.
y SALP Cycle Length Current MC 0516 guidance concerning the~ frequency of SALPJ evaluations states that the NRC will.normally review and eval-
,4 uste each power reactor licensee possessing an operating W
license or cunstruction permit'every 15 months.
Current.
exceptions include the following-
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Extensions in cycle length to 18 months in those i
o infrequent ceses when the regional administrator determines that the performance of a particular. utility 1
E or facility has been clearly superior.
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Reductions in cycle length to 12 months in those cases
%f when the' regional administrator determines that the performance of a particular ' utility or f acility warrants n.P a mcre frequent evaluation, such as in' the case of.
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licensees that were assigned a Category 3 performance-D i-rating -in several functional-areas during the previous evaluation.
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Performance of a SALP approximately' I month before the j
expected milestone date when a SALP evaluation will be j
4 4 used as part of a determination of the-readiness for new t!t plant startups or plant restarts from an extended outage or shutdown.
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Performance of SALPs at 12-month intervals for two consecutive evaluations for newly. licensed plants.
The staff reviewed the current guidance on SALP periodicity.
At issue was the determination of an appropriate cycle; length while allowing-for justifiable deviations. The results.of the review indicated that the current cycle length of 15 months is satisfactory for most licensees.
This period is short enough to maintain a focused NRC inspection and assessment effort g
ano long enough to allow improvements implemented by licensees j
to have some effect. Additionally, timely feedback to licens-h ees through the SALP process is necessary for identification of deficiencies or negetive trends.
Where licensees have demonstrated t high level of performante l'st is ahticipated to continue, existing extensions in cycle angth to 18 months j
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Reductions 'in, cycle length to 12 months continue To be ' warranted for licensees with significant problems or an overall low' performance level.
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t An additional consideration concerning SALP periodicity.
addresses the flexibility to adjust the, period to - better coordinate.SALP evaluations with otherl assessment._ program
. activities and is included-in the MC 0516 revision.. Also,
.,L under special circumstances and upon, conferring ~ with, the Director of NRR, the-suspension of the normal SALP period will b
be allowed for plants-in extended shutdowns, extended outages, or being decomunissioned.= The staff-believes-that these SALP~
periodicity guidelines as stated above, would' support the goals of the program and meet the needs.of the NRC.
F' Rising Performance Standards and Expectations
.. o The SALP progran is _a mechanism for assessing the quality of licensee activities and 'the degree to which 'a L 11censee is.
4 committed to improving performance. Although not:an objective of the SALP program, -the concept of= rising.. performance expectations is incident to the SALP process. -
Rising NRC expectations' result from the natural evolution. of.. industry improvements.
Current MC 0516 guidance addresses the concept of an environment where the standards and expectations of l
l perf ormance change cver time.
This issue of rising perform--
1 ance standards and expectations-and the current discussion of 1
thisl concept in MC 0516 were reviewed.
The staff found that-7b some minor changes to NC 0516 were necessary.
.The rationale for rising standards isE thatc NRC assessmentsL acknowledge the long-term self-improvementsi and rising: per-formance in the nuclear industry.. improvements in_ performance' are expected as the industry continually seeks increased plant reliability and enhanced overall performance'.
These improve--
ments are anticipated to occur over periods that encompass a few SALP cycles, it is necessary for the:NRC to monitor and to keep pace with these industry improvements in order to 3
maintain continuing qualitative assessments of licensee.
4 performance.
Although minor changes to the description of this concept cre contained in the revistch to MC 0516, the concept was determined to be both acceptable and realistic.
1 Responsibilities of the Regional Administrator o
The regional administrators (ras) manage the implementation of li the SALP program in their respective regions.
Specific responsibilities, as currently defined in MC 0516, are as L
follows:
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ras implement the - requirements of thisichapter within1 1
'their respective regions.
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. ith input from the SALP' Board,- ras issue the initial
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W SALP report; evaluate licensee comments and the adequacy-of licensee comunitments; issue the final SALP report; and m
direct reallocation of regional inspection resources, as
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ras establish. a schedule and determine a site for a meeting with the licensee.to ensure mutual understanding of the issues discussed intthe SALP report.
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ras ' provide recomunendations' to the Director. of NRR-for p
improving the SALP program.
h The role and the level of involvement of the ras in the SALP process were reviewed.
The study. f ound that ras remain relatively independent of the SALP Board ' process.
The-ras tend to " primarily involved in the oversight of the board results,., issuance of the initial and final SALP reports,'
H and in the SALP management meeting.
Although current MC 0516 guidance allows the ras to make substantive changes to the report, the staff review found that ras rarely do so. The RA provides a nianagement review:of SALP reports and ensures that' the current assessment of licensee' performance is clearly stated.
The staff believes that the current SALP process is well defined and that MC 0516 provides -sufficient guidance.
However, for unusual circumstances, significant deviations F
from the normal SALP program might be required.
In the
=MC 0516 revision, ras would be allowed to make such deviations-after conferring with; the Director of NRR and informing the-
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Deputy Executive Director for Nuclear Reactor Regulation, RegionalOperationsandResearch(DEDR).
j Responsiveness to NRC Initiatives The assessment of licensee performance is currently
!L implemented through the use of seven evaluation criteria. The m
criteria provide standard-guidance that the NRC applies to each functional area to categorize licenset. performance. - To provide consistent evaluation of licensee performance, several attributes are associated with each criterion to describe the characteristics applicable to the three performance categories.
The evaluation criteria and their associated attributes aid the NRC staff in understanding and evaluating licensee performance by ioentifying the causes and factors L
appropriate for cetegorization.
Although all of the attri-butes of the evaluation criteria are not necessarily appli-L cable to each licensee during each SALP period, the evaluation
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criteria are considered in the evaluation of each functional p
o area to the extent appropriate.
The current evaluation criteria are as follows:
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Assurance of e quality, including management-involvement :
<j and control.
2.
Approach to the identification and resolution of
' technical issues from a-safety standpoint..
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Responsiveness to NRC initiatives.-
4.
Enforcement history.-
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Operational and construction events (including response-y to, analysis. of, reporting of, and corrective actions y
for).
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Staffing (including management).
7.
Effectiveness of the training and qualifications program.
During-the staff review of areas related to the internal SALP assessment process, one of the' more significant issues.
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L the performance evaluation criterion " Responsiveness to NRC' H'
Initiatives."
The criterion was developed--to aid in the-
- j assessment of.a licensee's ability to resolve and respond to formal. NRC initiatives and. policies.
However, based on interviews, meetings, and the Regulatcry Impact Survey, it was apparent that the intent of this evaluation criterion was sometimes misconstrued and the industry saw the criterion had the potential for abuse.
Review of'this issue indicated that the attributes associated with this criterion are encomp(assed by attributes associated with cther evaluation criteria such as " Assurance of Quality" and "Appro6ch to the Resolution of Technical Issues from a r
p Safety Standpoint").
Consequently, the -staff will delete 4
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" Responsiveness to NRC ' Initiatives" as an evaluation l
criterion.
hr Cogosition of the SALP Board The composition of the SALP Board is multidisciplinary in nature and is intended to result in an integrated assessment of licensee performance.
Specific 6 tion of the boord's voting members does not limit presentations before the board by other NRC staff members when appropriate. The staff members closely y'
associated with a functional area are typically requested to discuss their views with the - SALP Board.
Voting members participete in board discussions of each functional area in order to contribute effectively to the assessment of the
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The Commissioners-11-w 11censee's performance and the identification of consion themes
- and trends of that. performance.
As ; a result, SALP ; Board 1
- deliberations are oriented toward reaching, s. consensus view'
'when possible.
The current SALP Board composition _ is as follows, with each member having a vote:-
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SALP Board Chairperson -(regional SES-level manager) j 2.
Senior Resident inspector.
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NRR Project Napager.
4.-
NRR SES-level manager 5.
Regional Projects Division-Director, or Deputy Director, or Branch Chief 6.
Regional Specialist Division Director,= Deputy Director,.
or Branch-Chief _(at least one from each Specialist Division).
7.
Others as designated by the regional administrator for any specific board, c
L A board quorum consists of a minimum of-six persons, with the l
chairperson an SES-level manager.
General'y, there are no more than nine persons on the board.-
The staff reviewed the composition of a SALP Board to deter-mine if enhancements were possible.
The options. considered 1 y
ranged from reducing the-board'to only five managerial-level o
i voting members -(which would have fixcluded the senior resident inspector and the project manager) te supplementing the cur-P IL rent board voting -membership. with specialist inspectors.
l-Although the current' board composition ~ was determined - to provide a desirable mix of dire _ct knowledge of the licensee and the plant, objectivity. and managerial overview, a minor change was made to provide balance to the board.
The change limits ~ regional divisional representation to one voting
- member per division (excluding: the board chairman).
SALPRepod I
i The SALP report is the culmination of the following assessment process:
Conduct of a LALP (draf t report and Board review).
Issuance of the init161 SALP report In.t least 2 weeks before the management meeting).
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- Conduct-of a public meeting with the licensee's manage--
J ment to discuss the assessment (90-days after the end of-I o
the assessment period).
i Consideration of any written response received from the 94
. licensee. A final SALP report is issued and includes any.-
written response received from c licensee and any changes; to the thitial SALP report based. on the regional; admin-.-
istrator's consideration of the-licensee's response (1501 e
days of ter the end of the assessment period).
P by the ' reevaluation included ' uss of' j
1ssuch miso covered J
Performance Indicator program dat6,.SALP report -length
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-consistency, and quelity.
Several changes L
timeliness, contained in the revision eodress impivvements in these-ere6bthe use of
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inclucing expohded guidance on restrictis.g o
Performance li.dicator program data when evaluating,licensec-performchte.
Althcugh - concisehess in the SALP report it t
desirable end encouraged,. a program 6 tic restraint-on report 4'
length-tight unmcessarily restrict the-communication cf = a 6
perforinance esssssinent. Consequently, nu change has been made l
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1 in this area.
. Currently, licensees receive the initi61 SALP report about 75 dtys af ter the end of the essessment period.
Althcugh this interval is consistent with those ut other major assessmcht 1
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reports,1mprovtcents in report -timeliness may be achievable through cifferent approaches tc report preparation. The staff.
will continue to-iesiew.this arch. The issues = of report t
l oublity -- 6nd - consistency.will Le acdresseo on a continuing basis through ; periodic evaluations ' of regicnal performance,
'NRR ' staff atter. dance at SALF boards, unc NRR staff review. of
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!; ALP reports. Iddition611y, lessens learnec chd observed gccd practicet vill be coixunicated to regional stuits.
4 The primary result of this program assessment was the confir-(
conclusion:
v.ation that' the SALP process is effective and fulfills the stated program objectives.
No major revisicnc to the program found to be necessary.
However. improvements and.
were clarifications to enhance the process are oesirable and ere incluced in the MC 0516 revision enclosed with this paper, t
coordination:.
The Of fice of the General Counsel has no legal objection to
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the contents of this papet,
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_The Commissioners a
- Recommendation:- That' the-Consission-approve-the staff's -implementation-. of the changes ? to MC,0516-in accordance with the ~ provisions of ;
NRC Manual Chapter 0201 "NRC ManagementL Directive Systems."
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ecutive Director-
-for Operations-
Enclosure:
As stated Commissioners' comments or.. consent should be provided directly to-the Office of the, Secretary by COB Tuesday, June 12, 1990.
Commission Staff-Office comments, if any, should'be submitted to the Commissioners ^.4LT Tuesday, June 5, 1990, with an infor-mation' copy to1the effice of-the Secretary.
If the paper is of P
such a nature that it Icquires additional time for. analytical review:and comment,.the Commissioners and the Office-of the Secretary should be apprised of when comments may be expected.
. DISTRIBUTION:
Commissioners
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-OIG-GPA REGIONAL OFFICES EDO ACRS-ASLDP ASLAP-SECY' l
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.U.S. NUCLEAR REGULATORY COMMISSION NRC MANUAL =
~ Volume: '0000. General Administration.
Y Part : 0500 Health and Safety NRR-CHAPTER 0516 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE m
-0516-01 COVERAGE AND BACKGROUND L
This chapter and its appendix describe the basic structure and overall proce-dures for implementation of the NRC program to assess licensee performance.
This program applies to all licensees of. power reactors with operating licenses or construction permits.
The Systematic Assessment of Licensee Performance (SALP) is an integrated agency effort to collect and evaluate available agency insights, data, and other l'
infonnation on a plant / site basis in a structured manner in order to assess and L
better understand the reasons for a licensee's performance. The manner in which a licensee meets regulatory requirements and the degree to which a licensee j
s seeks to improve perforniance are both measures of a licensee's connitment to o
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nuclear safety and plant reliability. Unacceptable performance is addressed y
through various NRC programs and policies, and the implementation of these activities should not be dilayed to await the results of a SALP. [Wnasseptable J
performanee-4s-addressed-threwgh-NRG-s-enforeement-pel4ey-and-the-4mple-mentat4en-of-this-pelfey-shewid-net-be-delayed-to-awaft-the-results-of-a SAkpe--Gemplianee-with-NRG-rules-and-regulattens-satisf4es-the-minimum-require-h L
ments-for-eentinued-speration-ef-a-fae4444yt-the-degree-to-whfeh-a-44eensee A pproved:
August 16, 1989
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC-0516-022 q
enseeds-regulatory reqw(rement6-46-a-meanwre-of-the-44eenseels-eesun44 ment-te-0
.nvalear-safety-and-plant-rel4abilityr).
r.
.The SALP process is used by the NRC to synthesize its observations of and l
insights into a. licensee's performance and to identify common themes or.symp-toms.. As such, the NRC needs to recognize and understand the reasons for a licensee's strengths as well as weaknesses. The primary product of the SALP The results
- I process is the SALP report addressed in Appendix B to this chapter.
L of the SALP process, as documented in the SALP report, are used to express The-SAbp-process-4s-a-means-of-enprest4ng NRC senior management's observations
'and judgments on licensee performance. It should not be limited to focusing vn l.
weaknesses, and it is not intended to identify proposed resolutions or solumns
[of) g problems. The' licensee's management is responsible for ensuring plant safety.and establishing effective means to measure, monitor, and evaluate the l
The SALP quality of all-aspects of plant design, hardware, and operation.
process.isintendedtofurtherNRC'sunderstandingof(1)howthelicensee's management guides, directs, evaluates, and provides resources for safe plant 1
operations,and(2)how[these-reneurees-are-app 44ed-and-used]effectivethese Performance indicat_ ors should not be a factor in,iudging effec--
actions are.
tiveness or ratino a particular SALP functional area. Althouch indicators may have relationships in varyina decrees to SALP functional areas, the Performance Indicators, Indicator Program is separate and distinct from the SALP program.
such as failures of a plant's safety systems or frequent forced outages due to Thus, events and-equipment failures, may be symptomatic of safety problems.
failures captured by the program may appear in SALP discussions or reports.
~
However, these SALP references are to be based on the underlying causes of poor L
A pproved :
August 16, 1989
T.*
LSYSTEMATIC ASSESSMENT OF-t >L NRC-0516 022 LICENSEE PERFORMANCE a
performance and not' on-the results of the Performance Indicator Program (Ref-
~
(
erence NRC Announcement f00). As a result,-emphasis isLplacej on understanding the reasons for a 11censee's performance in identified functional areas and on j
4 sharing this understanding with the licensee and the public. The SALP process i
is intended to provide meaningful feedback to a licensee's management ~and to be sufficiently diagnostic to provide a rationale for allocating NRC resources.
d
.0516-02 OBJECTIVES
}
021 To improve.the NRC regulatory program by providing a mechanism
.for focusing NRC management's attention on areas of concern.
i 1
022 To be. instrumental-in improving licensee performance by establishing-a basis for dialogue between NRC senior management and licensees specifically f
directed toward problem areas.
L 023 To provide a mechanism that focuses attention on the overall effectiveness of management. including underlying strengths and weaknesses.
024 To assist NRC management in making sound decisions regarding allo-cation of NRC resources used to oversee, inspect, and assess licensee i
performance.
t l-Approved:
August 16, 1989
~
~
- i'..
- . \\
[%,
SYSTEMATIC ASSESSMENT OF:
9' NRC-0516-022i LICENSEE-PERFORMANCE 0516-03 RESPONSIBILITIES AND AUTHORITIES X"
-i
[
031 The-Executive Director for Operations (EDO) provides oversight for
[
the activities described herein.
032 -The Director, Office of Nuclear Reactor Regulation (NRR):
9 a.
Implements the requirements of this chapter within NRR, l
b.
Monitors the SALP process; evaluates and develops SALP policy, criteria, and methodology; and assesses the uniformity and adequacy of the implementation of the program.
j l
033 The Directors, Offices of Nuclear Regulatory Research (RES), Anal-ysis and Evaluation of Operational Data (AE00), and Nuclear Materials Safety l
p and Safeguards -(NMSS), implement the requirements of this chapter within.
4 their respective offices.-
4 034 Regional Administrators:
Implement the requirements of this chapter within their respective a.
Regions or confer with Director, NRR, and~ inform the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and'Research (DEDR) when contemplating significant deviations from the requirements-or guidelines of this chapter.
Approved: August 16, 1989
v-3 SYSTEMATIC ASSESSMENT OF:
LICENSEE PERFORMANCEt NRC-0516-022 P
b.
With input from the SALP Board, issue the initial SALP, report; evaluate licensee comme'nts' and the adequacy of' licensee commitments;.
t issue the final-SALP report; and direct reallocation of Regional-inspection resources, as appropriate.
i lc.
Establish a schedule and determine a site'for a meeting with the 4
l licensee to ensure. mutual understanding of the issues di; cussed in the SALP report.
Si
' d '.'
Provide to the Director, NRR, recommendations for improving the-
.SALP program, t
0516-04 EVALUATION FREQUENCY The NRC will normally review and evaluate each power reactor licensee pos-
.l' sessing an operating license or construction permit every 15 months'except in the following> instances:
i n-thes e-i nf requent-c as e s-whe n-the-Re gi onai-Admi ni s trate r-de te rmi ne s a.-
that-the performance-of-a particciar-etility-or-faciiity-has-been -
cleariy-seperier--the-f requency-of-the-S AtP-evaiention-mey-be-ex-tended-up-to-18-months.
In those cases where a regional adminis-a trator determines that a particular utility or facility has demon-strated a high level of performance and this level of performance is i
anticipated to continue, the frequency of the SALP evaluation may be extended to as much as 18 months.
Additionally, flexibility in
- r 1
Approved:
August 16, 1989
-l l
1 i
.o C'
~
. SYSTEMATIC ASSESSMENT OF NRC-0516-022 LICENSEE PERFORMANCE ad.justino SALP frequency is available in order to better coordinate i_
SALP evaluations with other prog am activities.
1 b.
When the Regional Administrator determines that the performance of a particular utility or facility warrants a more frequent evaluation, such as in the case of licensees that were assigned a Category 3 performance rating in several functional. areas during the previous evaluation, the period between SALP evaluations should be reduced
~ '
to about 12 months.
I c.
[When-a-SAtP-evaiention-wiii-be-esed-es part-of-a-determination-ef l
the-readiness-fer-new piant-starteps-er-piant-restarts-frem-an extended-eetage-er-shatdown-n-SAtP-evaiention-shecid-be-een-dected-approximately-1-month-before-the-expected-milestene-date.)
l When circumstances warrant, the normal SALP frequency may be suspended.
l_
These inf requent cases are anticipated to involve plants in extended i
shutdowns, extended outages, or decommissioning where some aspects i
of a SALP evaluathn might not be r?alicable.
Plants in these
, circumstances are typically covered by separate as.g y g nt and readiness review programs.
In these cases the regional aaminis-trator shall confer with the Office Director of NRR and document the basis for suspending the normal SALP frequency.
i l'
d;
- f a regional administrator determines that a SALP evaluation would 1
be useful in the determination of readiness for new-plant startups g
L 1
i i
Approved: August 16, 1989
[
a 4
4-SYSTEMATIC ASSESSMENT OF-NRC-0516-022 LICENSEE PERFORMANCE f
+
F or plant restarts from'an extended outage or shutdown, it should be conducted reasonably close to the expected milestone date.
(d.]e When a new operating license is issued, two consecutive SALP 2
evaluations should be scheduled at approximately 12-month intervals.
The first of these two evaluations should be scheduled for comple-tion approximately 12 months after the low power license is issued.
O The second of these two evaluations should be completed approxi-mately 12 months later.
Following completion of these two evalua-m tions, a determination would then be made on whether to place the licensee on a normal SALP schedule.
For licensees operating plants at more than one site, or operating plants at one site that are of significantly different designs, or operating plants at one site that may be in different stages (e.g., construction stage, pre-operational stage, or power ascension from an extended outage), independent assessments must be performed. For licensees operating plants at a multiple unit site, one assessment for a the functional area where there is commonality may be appropriate.
0516-05 EVALUATION PROCESS SEQUENCE The evaluation process, illustrated in Appendix A. Figure 1, Appendix-0516 -
pege-A is summarized as follows:
Conduct [ef) a SALP using the evaluation criteria of Appendix A.
a.
Approved: August 16, 1989
o' o
3 SYSTEMATIC ASSESSMENT OF NRC-0516-022 LICENSEE PCRFORMANCE y
r b.
[ issuance-of) Issue the SALP report. (by-the-Regienti-Administrator.)
t c.
Conduct a public meeting with the licensee's management to discuss s
the assessment.
( A-meeting with-the-iicensee's-management-wiii i
normaiiy be-condected-en-site-when-fensibie-to-fester) Normally, the meetino will be conducteo on the site or in the vicinity of the site to foster accessibility and a more widespread understanding of the NRC's views, d.
[Eensideration) Consider any written response received from the l
licensee.
A final SALP report will be issued and will include the (verbatim) written response received from the licensee and any l
changes to the SALP report based on the Regional Administrator's l
l>
consideration of the licensee's response.
e ---Svervias:-The-ratings-assigned to-individuai-fenetiensi-areas-are eniy-ene-aspect-ef-the-SALP process:-The-SALP-Beard-is-expected-to assess-each-futetionai-area in-such-a manner that-the-SALP-Board discussien feceset-en understanding-the-reasons-fer-the-ebserved-t-
L performance:-The-attributes-and-assessment-criteria provided-i n-Appe ndi x-A- s houi d-be-reli e d-en-to-de ve i ep-a- eni f orm-and-cons i s te nt-l L
approach - Af ter-assessing-nii-of-the-functionai-areas--the-SAtP-Beard-is-expected-to discuss-commonalities--if-any--among-the-f ane-tionai-areas;-This process of-reviewing-the-summary-resaits-from-the-standpoint-ef-identifying-commen enderiying-reasons-for-the-Approved:
August 16, 1989
x
'e SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
~iicensee's performance-is-the-basis-of-the-everview -The-everview-s he el d-ai s e-note-f eneti onai-are as-where-r ati ngs-have-changed-si nce-the-previens peried-and discuss the-reasons-for-such-changes:--The-everview-shecid-net-be-a-summary-statement-of-the-numerieti ratings-ef-the-individuai-fenetionai-areast-Rather--the-overview-is intended-to-be-a- sy nop s i s-e f-the-ende riyi ng-rea s ons --i n-the-vi ew-ef-NR6-managerst-fer-beth good-end peer-licensee performance-as-weii as-i f er-changes-in performance:-With-regard-te-feer-44eensee perfor-3 mance;-the-overview-deveieped-sheeld-be-someuhat-specific-se that-the-i i c e n s ee - may-b e - f ei ly-aware - of-the-m as-i n-whi c h-i nc re as ed-
]
ati l i ty-ma na geme nt-a tt e nti o n-i s-r e qui re d:
}
T e-emphasi t e-tepi c s-f or-c ensi de r ati on-bey ond-the-s pe ci fi e d-f unc ti ensi-areas;-NRR-wiii-identify-seieeted topies-for-inciosion-as part-of ' he-everview:-Tepies-seieeted-wiii-be-addressed-by-eii-SALP-Beards for-4 a-defined-peried--and-the-sammary-rescits-wiii-be presented-as part-
]
ef-the-everview:
,j 1
General guidance regarding the implementation of the SALP process is provided in Aprtadix B to this Chapter. Specific guidance for the implementation and conduct of the SALP process is contained in the operating procedures of each responsible Office and Region.
0516-06 FUNCTIONAL AREAS Functional areas represent a grouping of similar licensee activities. Each func-tional area evaluated will be assigned a rating as defined in section 0516-08.
Approved:
August 16, 1989 J
p SYSTEMATIC ASSESSMENT OF
[
LICENSEE PERFORMANCE I
NRC-0516-022 Although not all functional areas need be assessed in a given review, an explanation'should be given in the SALP report if a functional area appropriate to a licensee is not evaluated. The evaluation criteria and associated attri-butes against which the functional areas are to be evaluated are provided in Appendix A to this chapter. Note that performance indicators should not be a f actor in judgements about the ef fsetiveness or rating in a particular SALP functional area. It is inappropriate to make reference to performance indica-tor program results in arriving at a SALP rating.
The ratings assigned to individual functional areas are only one aspect resulting The SALP Board is expected to assess each functional area from the SALP process.
in such a manner that the sal,.P Board discussion focuses on understanding the
_ reasons for the observed performance.
The attributes and assessment criteria provided in Appendix A should be used to develop a uniform and consistent approach.
After assessing all of the functional areas, the SALP Board This is expected to discuss commonalities, if any, among the functional areas.
process of reviewing the summary results from the standpoint of identifying common underlying reasuns for the licensee's performance is the basis of the overview section of the report. The overview should also note functional e
areas where ratings have changed since the previous period and discuss the reasons for such changes.
To emphasi2a topics for consideration beyond the specified functional areas, NRR may identify selected topics for inclusion as part of the overview.
Topies selected will be addressed by all SALP Boards for a defined period, and the summary results will be included as part of the overview section of the report.
Approved:
August 16, 1989
-4 SYSTEMATIC ASSESSMENT OF.
rC-0516-022 LICENSEE PERFORMANCE 061 Operatino Phase Reactors L
a.
Plant Operations. This junctional area consists chit.ly of the con-trol and execution o.' activities directly related to operating a plant.
It is inteided to include activities such as plant startup, power operation, plant shutdown, and system lineups. Thus, it includes activities such as monitoring and logging plant conditions, normal operatior,1, response to transient and off-normal conditions, manipulating the reactor and auxiliary controls, plantwide house-l keeping, control room professionalism, and interface with activities that support operations.
b.
Radioloaical Controls. This functional area consists of activities directly related to radiological controls, including occupational radia-tion safety (e.g., occupational radiation protection, radioactive materials and contamination controls, radiation field control, radio-logical surveys and monitoring, and as low as is reasonably achiev-L able programs), radioactive waste management (i.e., processing and onsite storage of gaseous, liquid, and solid wastes) radiological effluent control and monitoring (including gaseous tnd liquid efflu-ents, offsite dose calculations, radiological environmental monitor-ing, and confirmatory measurements), water chemis'ry controls and transportation of radioactive materials (e.g., procurement of pack-ages, preparation for shipment, selection and control of shippers, receipt / acceptance of shipments, periodic maintenance of packagings, L
and point-of-origin safeguards activities).
Approved: August 16, 1989 1
l i
i, y
1 c
SYSTEMATIC ASSESSMENT 0F
.NRC-0516-022 LICENSEE PERFORMANCE
'l i
c.
Maintenance / Surveillance. This functional area includes all activ-ities associated with either diagnostic, predictive, preventive or 1
corrective maintenance of plant structures, systems, and components; i
procurement, control, and storage of components, including qualifi-cation controls; installation of plant modifications; and main-tenance of the plant physical condition. It includes conduct of all l
surveillance (diagnostic) testing activities as well as all inservice
]
inspection and testing activities. Examples of activities included are instrument calibrations; equipment operability tests; post-maintenance, post-modification, and post-outage testing; containment leak rate tests; special tests; inservice inspection and performance i
tests of pumps and valves; and all other inservice inspection t
activities, d.
Emeroency Preparedness. This functional area includes activities related to t'e establishment and implementation of the emergency
]
plan and implementing procedures, tuch as onsite and offsite plan development and coordination; support and training of onsite and offsite emergency response organizations; licensee performance dur-l~
ing exercises and actual events that test emergency plans; admini-stration and implementation of the plan (both during drills and l
l-actual events); notification; radiological exposure control; recovery; protective actions; and interactions with onsite and off-site emergency response organizations during exercises and actual events.
Approved:
August 16, 1989
SYSTEMATIC ASSESSMENT OF.
LICENSEE PERFORMANCE l
e NRC-0516-022 Security. This functional area includes all activities that ensure e.
the' security of the plant, that is, all aspects of access control, security checks, safeguards, and fitness-for-duty activities and controls.
f.
Engineerino/ Technical Support. The purpose of this functional area
{
is to address the adequacy of technical and engineering support for f'
1 all plant activities. It includes all licensee activities associated with the desigri of plant modifications; engineering and technical 1
support for operations, outages, maintenance, testing, surveillance, and procurement activities; training; and configuration management, j
f Safety Assessment / Quality Verification. This functional area includes g.
all licensee review activities associated with the implementation of I
licensee safety policies; licensee activities related to amendment, exemption and relief requests; resolution of respense-to generic letters, bulletins and information notices; and resolution of THI items and other regulatory initiatives. It also includes licensee activities related to the resolution of safety issues, 10 CFR 50.59 reviews,10 CFR Part 21 assessments, safety committee and self-assessment activities, analyses of industry's operational experience, root cause analyses of plant events, use of feedback from plant quality assurance / quality control (QA/QC) reviews, and parucipation in self-improvement programs. It includes the effectiveness of the licensee's quality verification function in identifying and correcting j
Approved: August 16, 1989 i-i
y 6
i
[
eif'W'"
' SYSTEMATIC ASSESSMENT OF j
NRC-0516-022 LICENSEE PERFORMANCE
.a substandard or anomalous _ performance, in identifying precursors of I
h potential problems, and in monitoring the everall performance of the a
plant.
h.
Other (As Needed). For example, when plants are in extended shut-l downs, it may be more appropriate to address shutdown operations in l
P lieu of plant operations. For readiness assessments, SALP Boards may need to consider activities that take place over a shorter interval, l
such as startup testing.
Additionally, in special cases where unique licensee activities, problems or events are evident, it may be useful to employ a new functional area or split existing functional areas.
062 Construction Phase Reactors Soils and Foundations. This functional area includes all activities a.
pertaining to soils and foundations related to the construction of theultimateheatsinkandmajorstructures.Specifically,this covers, as applicable, subgrade investigation and preparation, fill materials and compaction, embankments, foundations and associated I
laboratory testing, and related instrumentation and monitoring systems.
I b.
Containment, Major Structures, and Major Steel Supports. This func-tional area includes all activities related to the structural con-crete and steel used in the containment (including the basemat),
major structures, and major steel equipment supports. It covers all I
Approved: August 16, 1989
~'
i c:
i SYSTEMATIC ASSESSMENT OF NRC-05163022 LICENSEE PERFORMANCE l
i aspects of structural concrete (e.g., reinforcing steel; concrete
~
1 bitching, delivery.. placement, in-process testing,'and curing; liner J
plate erection and fabrication; and containment post-tensioning),
structural steel used in safety-related structures (welded and J
bolted), and major steel equipment supports (for reactor vessel, reactor coolant pumps, steam generators, pressurizer, polar crane, tanks,heatexchangers,etc.).
c.
Pipino Systems and Supports.
This functional area includes those piping systems cescribed in the licensee's safety analysis report j
(SAR) that affe:t the safe operation of the plant. It includes those activities and quality checks (e.g., f abrication, installation, con-figuration, welding, nondestructive examination, and preservice inspection) necessary to ensure compliance with the applicable codes and other requirements specified in the safety analysis report,
{
specifications, and implementing procedures.
d.
Mechanical Components. This functional area covers mechanical compo-nents such as pressure vessels, reactor vessel internals, pumps, and i
valves located in, and attached to, the piping systems described under the preceding functional area. The primary emphasis is on dis-crete components rather than piping or systems, Auxiliary Systems. This functional area includes those auxiliary e.
systems in the nuclear facility that are essential for the safe shutdown of the plant or the protection of the health and safety of Approved:
August 16, 1989
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC-0516-022 l
the public. It includes systems such as the heating, ventilation, and air conditioning; radwaste; fire protection; and fuel storage and handling systems, f.
Electrical Equipment and Cables. This functional area includes important electrical components, cables, and associated items used in the electrical systems of the plant, such as motors, transformers, batteries, emergency diesel generators, motor control centers, switchgear, electric raceways, cable (power, control, and instru-ment), circuit breakers, relays, and other interrupting and protec-4 tive devices.
Instrumentation. T,iis functional area covers instrument components g.
and systems that are designed to measure, transmit, display, record, and/or control various plant variables and conditions. The reactor protection system and the engineered safety features actuation system are examples of covered plant systems. Also included are devices such as sensors, transmitters, signal conditioners, con-trollers and other cctuating devices, recorders, alarms, log',c devices, instrument air supplies, racks, and panels, h.
Engineerina/ Technical Support. The purpose of this functisnal area is to address the adequacy of the technical and engineeriiig support for all plant activities. It includes all licensee activities asso-ciated with the design of the plant; engineering and technical support for maintenance, testing, surveillance, procurement, and Apprcved: August 16, 1989 l
3 SYSTEMATIC ASSESSMENT OF -
LICENSEE PERFORMANCE NRC-0516-022 i
i preoperational, startup, and operational activities; training;.and.
configuration management (including maintaining design bases and:
safety mt.cgins),
t t
Safety Assessment / Quality Verification. This functional area includes i
all licensee review activities associated C th the implementation of licensee safety policies; licensee activities related to exemption and re' lief requests; response to generic letters and bulletins; and resolution of TMI items and other regulatory initiatives. In addition, it includ2s licensee activities related to the resolution of safety issues, 10 CFR 50.55 requirements, 10 CFR Part 21 assessments, safety-comniittee and self-assessment activities, analyses of industry's operational experience, use of feedback from plant QA/QC reviews, and participation in self-improvement programs.
It includes the effec-tiveness of the licensee's quality verification function in identify-ing and correcting substandard or asomalous performance, in identify-ing precursors of potential problems, and in monitoring the overall performance of the plant,
~
s j.
Others (As Needed). For reactors in the preoperational phase, func-tional areas listed for either operating phase reactors or construc-tion phase reactors should be selected, as appropriate. For reactors in the startup phase, funrtional areas listed for operating phase reactors should be utilized. Additionally, in special cases where unique licensee activities, problems or events are evident, it may be useful to employ a new functional area or split existing functional areas.
Approved: August 16, 1989
3 o
SYSTEMATIC ASSESSMENT OF NRC-0516-022 LICENSEE PERFORMANCE l
0516-07 EVALUATION CRITERIA i
i
/
Licensees will be evaluated in the functional areas described in sections 0516-061 and -062 using the following evaluation criteria. Appendix A to this chapter describes a number of attributes for each evaluation criterion and 3
provides guidance on using these criteria to determine assign a performance rating. The evaluation criteria are as follews:
t a.
Assurance of quality, including management involvement and control; i
b.
Approach to the identification and resolution of technical issues from a safety standpoint; i
[er -Responsiveness-to NRE-initiativest) i (d]c. Enforcement history;
[e]d.0perational and construction events (including response to, analy-sis of, reporting of, and corrective actions for);
[f]e. Staffing (including management); and
[g]f. Effectiveness of training and qualifications program.
Approved: August 16, 1989 i
a
~
SYSTEMATIC ASSESSMENT OF NRC-0516-022 LICENSEE PERFORMANCE l
0516 08 PERFORMANCE RATINGS j
k The SALP program is a mechanism to assess the quality of licensee activities j
and safety performance in selected functional areas the-degree te-which-e l i c e ns e e - i s
- c ommi t t e d-to-s upe ri e r-p e r f orma nc e It should be noted that NRE's-standard-for-measuring-licenseeperformance-reflects NRC assessments acknowledQe the long-term self-improvements and rising performance in the nuclear industry. [and-is-continually increasing).
Licensees assioned earning 1
a Category I rating in a functional area have clearly demonstrated superior performance, which may justify justifying some relaxation in NRC oversight.
Conversely, licensees assioned earning a Category 3 rating in a functional area ere of concern to NRC and will receive [sobstantial) consideration of additional NRC interaction and oversight to ensure performance improvements, j
The functional area being evaluated may have some attributes associated with a rating of Category 1 and others that are aligned with either a Category 2 or 3 rating. The final rating for each functional area will be a composite rating of -
the attributes tempered with judgment as to the significance of individual items.
The assignment of a rating is a [seriens] judgment based on a know1-edgeable balancing of experiences and safety significance by senior NRC managers and staff. Statistical or numerical balancing is inappropriate.
The performance categories used when rating licensee performance are defined as follows:
a.
Category 1.
[ ti c e ns e e-ma na geme nt-a tt e nti o n-and-i nv ol v eme nt-are-re a d-iiy-evident-and piace-emphasis-en-seperier performance-of-necitar i
Approved:
August 16, 1989
f y'p L 1
SYSTEMATIC ASSESSMENT OF 4
LICENSEE PERFORMANCE-
. NRC-0516-022 i
safety or-safeguards-activities;-with-the-restiting-performance-sub-i stantiaity-exceeding-regoistory-requirements:--ticensee-researces a re-ampi e-and-e f f e cti v ely-es e d-s e-that-a- hi gh-i e v ei-of-pi ant-end i
pe rsonnei - pe r f ormanc e -i v - be i ng-s c hi e v e d:-- Re dec ed-NRE-atte nti on-may
+
t be-appropriate.] Licensee management attention to and involvement in nuclear safety or safeouards activities resulted in a superior f
level of performance.
NRC will consider reduced levels of inspection t
effort.
i b.
Category 2. [ticensee-management-attentien-to-and-inveivement-in-the perferesnee-of-necitar-safety-er-safeguards-activities-are geod:-The iieensee-has-attained-a-ievei-ef-performance-above-that-needed-te me et-re gei story-requi reme nt s:- ti ce ns ee-re s e arc e s - are-ade quate - a nd reasonably-eiiecated-se-that good-piant-and-personnei performance-is bei ng-achi ev e d:- NRE-atte nti en-may-be-mai ntai ned-st-ne rmai-i ev ei s t )
Licensee management attention to and involvement in nuclear safety or safeguards activities resulted in a good level of performance.
NRC will consider maintainino normal levels of inspection effort.
i Category 3. [ticensee-management-attention-to-and-inveivement-in-the
[
c.
perf ormance-of-neci tar-s af ety-et-s af egeerds-acti vi ti es - are-net sofficient--The-iieensee's-performance-does-net-significantly-exceed th at-nee de d-te-mee t-mi ni mai - r e gei sto ry-re qui reme n ts :- ti c e ns e e resecrees-appear-te-be-strained-er-net-effectively esed:-NRE-atten-ti on-s houl d-be-i ncre as e d-abov e-ne rmai -i evei s; ) Licensee management attention to and involvement in nuclear safety or safeguards activi-l Approved: August 16, 1989 1
SYSTEMATIC ASSESSMENT OF i
ot LICENSEE PERFORMANCE NRC-0516-022
'l ties resulted in an acceptable level of performance.
Performance at
.l this level is of concern to the NRC because a decrease in performance i
may approach or reach an unacceptable level.
NRC will_ consider i
increased levels of inspection effort.
d.
Category U.
Licensee management attention to and involvement in nuclear safety or safeauards activities resulted in an unacceptable level of performance.
Licensee efforts to identify or correct the underlying causes of the unacceptable performance have been ineffec-tive.
NRC attention and inspection resources will be increased.
NRC will act at the time unacceptable performance is detected and not wait until the SALP review.
Thus a Category U ratina will reflect n prior NRC determination of unacceptable performance.
Generally, use of a Category U ratina will be confined to plants that are or have been in a shutdown condition, or, if operatina, under a performance-based NRC order.
t e.
Category N.
Insufficient information exists to support an assessment of licensee performance.
These cases would include instances in which l
a rating could not be developed because of insufficient licensee activity l
or insufficient NRC inspection
('
The SALP is not intended to be a substitute for NRC's enforcement policy.
L Enforcement action should not await the outcome of a SALP, but should be taken at the time the unacceptable action (s) or event (s) occur (s). In this ragard, the t
SALP process can assist NRC management by providing perspective, but it is not a Approved:
August 16, 1989
I SYSTEMATIC ASSES 5 MENT OF o
NRC-0516 022 LICENSEE PERFORMANCE r
7 substitute.for effective enforcement action. Where licensees are incapable of consistently meeting (minimai) regulatory requirements, the affected plants will be considered for escalated enforcement action, including shutdown.
I 0516-09 PERFORMANCE TREND The SALP report may include an appraisal of the performance trend in a func-j tional area for use as a predictive indicator.
Licensee performance during the assessment period should be examined to determine whether a trend exists.
i Normally, this performance trend should only be used if both a definite trend is diteernable and continuation of the trend may result in a change in perform-3 ance rating. The performance trend is intended to predict licensee performance l
during the next assessment period and should be helpful in allocating NRC resources. Of particular interest are those licensees with a Category 3 perform-ance rating.and a declining trend.
If senior NRC management has not been 1
previously informed, these situations should be brought to the attention of the Director, Office of Nuclear Reactor Regulation; the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research; and the Regional Administrator.
Determination of the performance trend should be made selectively and should be reserved for those instances when it is necessary to focus NRC and licens-ee attention on an area with a declining performance trend, or to acknowledge an improving trend in licensee performance.
Approved:
August 16, 1989
f,.
e A.
SYSTEMATIC ASSESSMENT Of NRC-0516-022 LICENSEE PERFORMANCE
.i The trend, if'used, is defined as:
a.
Improvino. Licensee performance was detettiined to be improving during the assessment period.
4 b.
Declining. Licensee performance was determined to be declining during the assessment period and the licensee had not taken meaningful steps to address this patterr..
j 0516-10 BASIC REQUIREMENTS 101 Applicability. This chapter and its appendlx apply to and must be implemented by NRC Headquarters and Regional Offices.
102 Appendix 0516.
This appendix consists of Appendix A, " Evaluation Criteria," and Appendix B, "SALP Implementation."
o l
.u Approved: August 16, 1989
qq,=
o Le
, c.
i t
APPENDIX A F
EVALUATION CRITERIA J
The assessment of licensee performance is implemented through the use of six evaluation criteria. The criteria provide standard guidance that tne NRC shall apply to each functional area to categorize licensee performance.
L
' To provide consistent evaluation of licensee performance, several attributes associated with each criterion are listed in Table 1 to describe the char-
'acteristics applicable to the three categories of acceptable performance.
The six criteria and their associated attributes will aid the NRC staff in understanding and evaluating licensee oerfcrmance by identifying the causes and factors appropriate for categortzation. It is not intended that considera-tion of these attributes influence established programs of the agency. For example,'it is not intended that the staff perform specific inspections to evaluate attributes. It is expected that during the implementation of estab-
[
lished programs, the staff will observe many of the attributes that describe performance. Awareness and consideration of these attributes should assist the staff in its observation of licensee performance during routine activities, j
4 i
l
4 All of the attributes of the evaluation criteria are not necessarily applicable to each licensee during each SALP period. For example, the observed perform-ance within a functional area may be insufficient to allow consioeration in the assessment. However, the evaluation criteria should be considered in the evaluation of each functional area to the extent appropriate.
All available information should be analyzed by the SALP Board and the Re-gional Administrator, and its significance, whether it be positive or negative, should be weighed. If information is scarce or nonexistent, a decision regard-ing the performance category as it relates to an attribute should not be forced.
Tables 2 and 3 provide a matrix of functional areas by evaluation criteria that may be useful to the SALP Board in assessing and recording licensee performance.
When using the evaluation criteria and associated attributes to assess Note:
a licensee, unacceptable performance (Category U) would be indicated by levels of performance lets than those associated with Category 3.
i
~ ' ~ - - -- -
~___.____
m
~~-------- - - -
__m_._
i
.[
SYSTEMA 11C ASSESSMENTOF UCENSEE PERFORMANCE NRC Appendix 0516 Figure 1 i
SALP EVALUATION PROCESS SCHEDULAR GOALS End of Assessment i
Period i t SALP Board i
Preparation t
I t SALP Board.
Meeting 1 r
. Initial SALP Report issuance i f 1 r Meeting Within with the Ucenser, 90, days 1 r i r Ucernee Within Resr,onse 30, days 1 r i r Final SALP within Report issuance 30 days t
Approved: August 16,1989 A1442
~
TABLE 1 EVALUATION CRITERIA AND ATTRIBUTES FOR ASSESSMENT OF LICENSEE PERFORMANCE 1.
Assurance of Quality, Including Management Involvement and Control Category 1 Category 2 Category 3 9
a.
There is consistent eviderre a.
There is evidence of prior a.
There is little evidence of of prior planning and planning and assignment of prior planning and assignment assignment of priorities; priorities; procedures for of priorities; procedures for.
l l
procedures for control of control of activities are control of activities are poorly-l activities are well stated, stated and defined.
stated or not well understood.
controlled, and explicit.
b.
Policies are well stated, b.
Policies are adequately stated b.
Policies are poorly stated, disseminated, a M under-and understood.
poorly understood ot-nonexistent.
i standable.
I c.
Decisionmaking is consist-c.
Decisionmaking is usually at a c.
Decisionmaking is seldom at a l
ently at a level that ensums level that ensures adequate level that ensures adequate adequate management review..
management review.
management review.
. ~..
~...
w
-d.
Corporate management is fre-- d.
Corporate management is usually d.
Corporate management is seldom quently-and effectively involved in site activities in er ineffectively involved in involved in site activities.
an effective manner.
site activities.
Engineering evaluations are Engineering evaluations are e.
Engineering evaluations are e.
e.
consistently technically generally adequate and records.
frequently inadequate and adequate and records and and plant performance data are records and plant performance plant performance data are generally complete, well data are not complete, well complete, vall maintained, maintained, and available.
maintained or available.
and available.
f.
Corrective action is f.
Corrective action is usually f.
Corrective action is not timely effective as indicated by taken but may not be effective
_or effective and generally ad-lack of' repetition of-in correcting the root cause dresses synytoms rather than events.
of the problem, as indicated by root causes, as indicated by occasional repetition of events.
repetition of events.
~
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g.
Safety review committees g.
Root cause analyses and self-g.
Corporate management does not GSEG, onsite, of fsite, assessments are occasionally-appear to rely on self-assessment etc.) and feedback from evident and sometimes result to ensure quality in activities.
QA/QC activities are used in improvements.
to provide critical self.
assessments to the corporate management and to improve work activities.
4
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4 eb 1
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TABLE 1 (Continued)
E Approach to the Resolution of Technical Issues from a Safety Standpoint 2.
Category 3 Category 2 Category _1 Understanding of issues is Understanding of issues is a.
Clear understanding of a.
a.
frequently lacking.
issues is demonstrated.
generally apparent.
b.
Conservatism is routinely b.
Conservatism is generally b.
Minimum requirements are met.
exhibited when potential for exhibited.
safety significance exists.
Approaches are often viable, but Approaches are viable and c.
Approaches are technically c.
c.
lacking in thoroughness or depth.
sound and thorough in almost generally sound and thorough.
all cases.
d.
ISEG and safety review d.
Problems often recur before d.
Critical self-assessment is committees are routinely and they are effectiveiy resolved.
lacking; therefore, problems are not identified until they effectively used to identify become evident.
underlying problems before they become issues.
Il
,a
~
e.
Resolutions are timely in e.
Resolutions are generally-e.
Resolutions are often delayed.
almost all cases.
timely.
f.
10 CFR 50.59 reviews are f.
10 CFR 50.59 reviews are done f.
10 CFR 50.59 reviews are not well we') documented and demon-well, but frequently lacking in documented and reflect a minimal strate a technical documented detail or technical analysis.
rationale.
technical basis.
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o
.o.
TABLE 1 (continued) l 3.
Enforcement History l
\\
l Category 1 Category 2 Category 3 i
l a.
Major violations are rare a.
Major violations are rare a.
Multiple major violations or 1
and are not indicative of and may indicate minor program-programmatic breakdown is l
programmatic breakdown.
matic breakdown.
indicated.
l b.
Minor violations are not b.
Multiple minor violations b.
Minor violations are repetitive repetitive and not indicative or minor programmatic breakdown and indicative of programmatic of programmatic breakdown.
is indicated.
breakdown.
c.
Corrective action is prompt c.
Corrective action is timely c.
Corrective action is delayed or and effective.
and effective in most cases.
not effective.
d.
Root cause analyses are d.
Root cause analyses are d.
Root cause analyses are super-effective as evidenced by frequently ineffective.
ficial, deal only with evident problem, and are not effective lack of recurrence.
in preventing recurrence.
TABLE 1 (continued)
'~
4.
Operational and Construction Events Category 3 Category 2 Category 1 Frequent significant opera-Occasional significant opera-a.
Few significant operational a.
a.
tional or construction events, tional or construction events, or construction events, at-attributable to causes under the attributable to causes under the tributable to causes under licensee's contvol, have occurred licensee's control, have occurred the licensee's control, have that are relevant to this occurred that are relevant that are relevant to this functional area.
functional area.
to this functional area.
b.
Events are promptly and b.
Events are reported in a timely b.
Events are frequently reported late or not completely.
mar,ner; some information is completely reported.
occasionally lacking.
. -~
Events are poorly identified or Events are accurately identi-c.
Events ere properly identi-c.
c.
analyses are marginal; events fied and analyzed.
fied, but some analyses are are associated with program-marginal.
matic weaknesses.
fr..
-' - 1 d.
Deficiencies-.in man--
- d.
Deficiencies in man-machine
.d... Deficiencies-in man-machine.
>+;l machine interface (e.g., in interface result-in personnel interface repeatedly _ result;in human engineering design and errors, but effective correctivc personnel errors;
' actions are implemented.
procedures) rarely result.
in personnel errors.
m i
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~
TABLE 1 (continued)
- 5.
Staffing (Incduding Masagement)
Category 3 Category 2 Category 1 Positions are poorly. identi-
~ Key positions are identified,
~
.a.
Positions are identified, a.
a.
"fied,'or authorities and respon--
and authorities and responsi-and responsioilities'are sibilities are ill defined.
defined.
bilities are well defined.
Key positions are left vacant for b.
Vacant key positions are usual-b.
b.
Vacant key positions are extended periods of time.
filled on a priority basis.
ly filled in a reasonable time.
Very little expertise is' avail-Expertise is usually available c.
Expertise is available with-c.
c.
able within the staff; ttzere is-within the staff; consultants in the staff; outsitie consul-excessive _ reliance on consultants; are appropriately used; staffing tants are rarely needed; staffing is weak;or minimal as staffing is ample as indi-is adequate as indicated by indicated by excessive backlog or-
~
. occasional difficulties with cated by control over backlog overtime.
backlog or overtime.
and overtime.
.,,A
, s.
.a
~k" l :.
+
d.
Experience levels for manage-d.
Experience levels for w.anagement d.- Experience levels-for. management
^- /A'
~
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ment and operations personnel
. and operations' personnel meet-and operations personnel are be '
exceed commitments made by commitments made by licensee at low dommitments made by. licensee licensee at time of licensing.
time of licensing.
' at time of licensing.
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a TABLE 1 (continued)
- 6.
Effectiveness of Training and Qualification Program Category 1 Category 2 Category 3-a.
Training and qualification a.
Training and qualification pro-
-a.
Training and qualification program makes a positive con-gram contributes to an adequate
' program is found to be the major.
tribution, commensurate with understanding of work and fair
- contributing factor to poor procedures and 4 ffing, to adherence to procedures, as understanding of work, as'indi-the understanding e' work and indicated by a modest number of cated by numerous procedural adherence to procedures, as personnel errors.
..olations or personnel errors.
indicated by few personnel errors.
b.
Training program is well b.
A defined program is implement-b.
Program is either lacking, defined and implemented with ed for a large portion of the poorly defined, or ineffectively.
1 dedicated resources and a
- staff.
applied for a significant segment means for feedback of expe-of the-staff.
rience program is applied to nearly all the staff.
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ewiie.ieni..
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.y Inadequate training could ecca- -c.. Inadequate training could Inadequate' training could c.
c..
rarely be traced as'a root
- siona11y be traced as a root
~
regularly be traced as a root cause of-major or minor events' cause' of-major. or minor. events.
cause' of major-or minor events ~
or problems occurring during
-or problems occurring during
_.or problems occurri_ng during the rating period.
-the rating period, the rating period.
{
~
d.
Procedures and policies
'd.
Procedures and policies are d.
Procedures and policies are y ~.
occasionally violated.
are followed.
rarely violated.
a
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'*2 SYSTEMATIC ASSESSMENT'0F l
[
LICENSEE PERFORMANCE NRC APPENDIX 0516 o
by
}
E y
q
['
-APPENDIX B=
j SALP IMPLEMENTATION'-
y t, m.-
I..
SALP BOARD ASSESSMENT l
I
' A. -
SALP Board Preparation y
Each Region shall:
1.
Issue a memorandum establishing the assessment period, due date for SALP Board; input, and scheduled dates for the SALP Board meeting, licensee management meeting and issuance of initial and final SALP L
-reports for all facilities within the Region scheduled for a SALP 1 dur.ing the fiscal year. The Regions shall send this^ memorandum to NRR, incinding the NRR SALP coordinator, NMSS, AEOD, RES. and,the EDO t
by. the end of the preceding fiscal year. The Regions shall provide
,1 any changes to SALP schedules to these offices.
The applicable SALP-data'in SINET should be updated as appropriate.
SALP Board members should be notified promptly of unavoidable scheduling problems to-j L
-facilitate coordination of alternative meeting dates.
i 2.
Prepare a draf t working copy of the initial SALP report.
l I
Integrate SALP report'irputs. NRR shall provide written input y<
a.
for each functional area as appropriate.
l a
B-1 Approved: June 6, 1988
-e-
r:
s-
- 4,
^
1 y
a f#
SYSTEMATIC ASSESSMENT.0F:-
LICENSEE PERFORMANCE NRC APPENDIX 0516 Pfeparelthe Supporting Data Summary section~of O e report.
b.
(See' Exhibit I for format.).
i I
, Prepare a performance analysis for each of the functional areas.=
c.
d.'
.Is, e T.tse draft working copy of the 'initisi SALP report to SALP7 j
Board participants before the SALP Board meeting date'.-. Note..that tiis version should not contain recommended licensee performance-ratings.
e i,
B.
SALP' Board Meeting l
1.
The SALP Board meetingh-which-shecid-be-heid-within-45-days-ef-the end-of-the-assessment peried;] will be conducted in accordance with
-1 the Region's SALP implementation procedures.
l~
2.
The composition of the SALP Board is multidisciplinary in nature and.
-is intended to result in an integrated assessment of licensee per-formance. Specification of the Board's voting members is not meant in any way to limit presentations before the Board by other NRC staff members when appropriate. Rather, the staff members closely
~
associated with a functional area should be requested to discuss =
q their views with the SALP Board.
Voting members are expected to participate in Board discussions of each functional area in order to contribute effectively to the assessment of the licensee's performance and the identification 01 B-2 Approved: June 6, 1988
O p :-
3-g.
'SY'STEMATIC ASSESSMENT OF" NRC~ APPENDIX OS16L LICENSEE PERFORMANCE o
commonithemes and symptoms'of that performance.-To effectively.
support the coals'of the Overview section of the report, it is j
.s '
important that the board votina membership remain constant durina.
- I the eval'uation process. As a result, SALP Board deliberations'should
~
be oriented toward reaching a consensus view when possible. The~ SALP Board composition shall be es'follows with'each member having_a vote:
I SALP Board Chairperson who is a Reaional SES-level manaaer a.
e selected f rom either e. or f. ' below; (Regionai-SES-ievei-manager) i i-b.
Senior Resident Inspector; c.
NRR Project Manager o
d.
NRR SES-level manager;-
i e'.
-One of the followina: -Regional. Projects Division Director, Deputy Director, [er) Branch Chief [--and, or Section Chief; f.
From each Specialist Division one of the followina:
Regional.
Specialist Division Director, Deputy Director, [er) Branch Chief f at-ienst-ene-f rom-each-Specialist-Bivision)[i]2 or Section Chief; Others.as designated by the Regional Administrator for a any-g.
specific Board.
1 B-3 Approved:
June 6, 1988 i
L
[x.
js
- 4
I
. SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 F
LICENSEE PERFORMANCE A Board quorum will consist of a minimum of six persons, with the:
Chairperson _an SES-level _ manager.. Generally, there should be no more than nine persons on the Board.
To enhance consistency in approach, Regional Administrators are.
~ encouraged to arrange for the periodic participation on SALP Boards of SES-level managers from other Regions [-] or NRR.
3.
During the SALP Board meeting:
a.~
The SALP Board members shall review and discuss the SALP-report. They shall ensure that each functional area section l
concisely conveys the Board's views, with selected exemples to illustrate key findings. They shall ensure that a conclusion has
.]
~
been reached regarding licensee performance within each functional area or alternatively confirm.that sufficient infor-mation is not available to support a conclusion regarding.
licensee performance. They shall ensure that the discussion of l
performance within each functional area -identifies common-'
l themes or symptoms cf that performance if known.
I; f)
-The SALP Board menbers shall evaluate licensee performance in b.
each functional area af ter considering the evaluation criteria with their associated attributes listed in Appendix A, Table 1.
Tables 2 and 3 may be used by the SALP Board members to as-
]
sist them in rating the licensee. The functional area ratings will f
be determined by a majority vote of the Board's voting members.
t Approved':
June 6, 1988 B-4 l.
~
.s qq '
SYSTEMATIC ASSESSMENT OF
'I 5
LICENSEE PERFORMANCE ~
NRC APPENDIX 0516 c.;.The SALP Board should recommend changes to-the NRC'inspec-tion program to be implemented at the specific facility, as sn t
appropriate.
1;,
e d.
The SALP Board shall: identify weaknesses and/or recommend t4 areas for licensee consideration so that improvement.in per-formance can be addressed.
g
.1 Th'e SALP Board Chairperson shall ensure that the licensee's i
p-e.
f overall performance is discussed and assessed with an emphasis i
on identified strengths and weaknesses, p
3.
a
(
L 4.
Following the SALP Board meeting, the SALP Board Chairperson shall provide to the Regional Administrator a the initial SALP Board report with its recommended ratings and overview. The Regional L,
t Administrator may.make substantive changes to the content of the
~
report before it is issued to.the licensee. If the changes ~ arc made, b
the Regional Administrator sho'E so inform the Board Chairperson.
L II.. ISSUANCE OF INITIAL REPORT The Regional Administrator shall sign and issue the initial SALP report (Exhibit 1) to the licensee at least two weeks before the meeting with the licensee.' Copies of the report should also be provided to the offices of the EDO, the Director of NRR, the Director of Enforcement, the Commissioners, B-5 Approved:
June 6, 1988
w<
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516
' LICENSEE PERFORMANCE =
and the NRR'SALP Coordinator. The initial ietter-transmitting-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 Local Public Document Room,-and the Institute of Nuclear Power Operations (Record Center, Institute of Nuclear Power Operations; 1100' Circle 75 Parkway; Suite 1500; Atlanta, GA 30339). Each SALP report will be assigned an inspection report number.
The transmittal 11etter for the initial SALP report should include:
1.
A' characterization of overall safety performance consistent with the Overview section of the SALP report. The transmittal letter should-strive to characterize NRC's confidence in or concern with the licensee's performance and the underlying reason (s) thereof, and should-place into perspective any significant events or findings
~that took place outside of the assessment period that bear on the evaluations in the report.
[The-transmittai-ietter-should-aise
- h ar a c te ri t e-any-ethe r-e ngei ng-e v e nts-ande p ro c e s s e s - rel ate d-to-the piant's performance-(i en-Senier-Management-Meeting-and-majer-team i n s p e c ti o n s 3 - to-e ns ure-co nfii eti ng-me s s ages-are-no t-tr a ns mi tte d-te e
the-iieensee;] The Regional Administrator should ensure the trans-mittal letter is consistent with the results of any other current events or processes related to licensee performance-(i.e., recent Senior Management Meeting results or ma.ior team inspections) to ensure conflicting messages are not inadvertently transmitted to the licensee.
t B-6 Approvedi June 6, 1988 l
n l"
' SYSTEMATIC ASSESSMENT OF
' LICENSEE PERFORMANCE NRC APPENDIX 0516 i
i l.
'2.
. Areas' or issuesLthat warrant discussion during the meeting'with the licensee.
3.
.A request for the licensee's written comments on and amplification 7
of, as appropriate, the SALP report within 30 days after the meeting-with the licensee. For all functional. areas rated as Category 3,'the.
transmittal letter must require a licensee response providing planned 1
corrective actions to achieve improved performance.
L III. MEETING WITH LICENSEE l
A.
General. A'public meeting with the licensee's management to discuss the l
L I
l-
. assessment will be held following' issuance of the initial SALP report.
(T he-mee ti ng-wi i i - be-e e ndecte d-en-s i te--i f-f essi bi e-- to-f ester-mere-wi de-spreed-anderstanding-among-the-iicensee's-staff-ef-the-NRE's-views-]
l-l' in the vicinity of the Normally, the meeting will be conducted on sita av site to foster accessibility and a more widespread understanding of the.
NRC's views.
'B.
Meeting Preparation 1.
The Region shall prov!de notification of the meeting with the' licensee with the same distribution as for issuance of the initial SALP report
.-(see-Appendix B,Section II).
d B-7 Approved':
June 6, 1988
gjo r.
si
'4i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516' 12.
The Region shall provide notification to.the media and-to State and local-government officials of issuance of the: initial.SALP report and
~
of the meeting with the licensee once the report has been released.
At least one week's notice before the meeting should generally be provided.
- 3...The licensee should be encouraged to have the' following management representatives participate in the-meeting:
a.
Senior corporate management representative; b.
. Management. officials responsible for the major functional areas; and c.
Site Manager.
-C.
Meeting with Licensee
.1.
The meeting should be conducted'within 90 days of the end of the assessment period.
2.
NRC representatives for this meeting should typically include the following-
-The Regional Administrator or Deputy Administrator (especially a.
if licensee performance has been rated as Category 3, or Category 2 with a declining trend);
B-8 Approved:
June 6, 1988
a
.g
' SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516-1 LICENSEE PERFORMANCE 3
b.
-SALP Board Chairperson; e
' Responsible Regional division director (s),~ branch chiefs, or c,
section chiefs, as appropriate;.
d.
NRR Project Manager and/or designated NRR SES-level
. manager; t
Resident inspector and/or assigned inspectors; and e.
f.
Public Affairs Officer, when media interest is anticipated.
3.
The Regional: Administrator, Deputy Administrator, or SALP Board Chairman, Project Division Director will chair the meeting.and.
-i discussions of the adequacy of the licensee's management control
' systems. These meetings are intended to provide a forum for a candid discussion of issues relating.to the licensee's performance. Those
~ aspects of the licensee's operation that need improvement.will be identified, as well.as the positive aspects of the' licensee's l
performance.
1 The licensee also will be given the opportunity to provide comments ;
.1 on the report in writing within 30 days after the meeting. Only written comments from the licensee must be subsequently addressed by'the Regional Administrator.
8 B-9 Approvedi June 6, 1988
~
~~
^
^
l E.,.
t 7/
1 N
. SYSTEMATIC ASSESSMENT:OF-LICENSEE PERFORMANCE' NRC APPENDIX 0516 T!q 9
m 4 '. :.SALP. management meetings with the licensee should be public' meet -
i' l d g ;,
_ ings, unless portions of the meetings involve discussion of matters g,
'that are not required to'be placed in the_public domain pursuant.to 10 CFR 2.790. For those portions, the meeting must be closed.
Members of the public, press and government efficials shceld be treated as. observers. Adequate notification of the SALP meeting-4 should be accomplished by the timely distribution to the Public-Document Room of.the letter scheduling the meeting to the licensee, with copies to the parties on the service list for the appropriate docket.
IV.
SALP REPDTT MRMAT. AND CONTENT o
A.'
General The' SALP report is _ considered to be a final report once the Regional' Administrator has signed the transmittal letter to the licensee following
-the meeting with the licensee and consideration of the-licensee's written response, if any.
~
-B.
Multiple Facility Licensees for multiple f acility. licensees, such as Duke Power Co., Tennessee Valley Authority, and Commonwealth Edison, the SALP package may address more than one site. However, each site shall have a separate SALP report (see Section 0516-04).
B-10 Approved:
June 6, 1988
4; 19 -
< SYSTEMATIC' ASSESSMENT OF:
.NRC APPENDIX 0516 LICENSEE PERFORMANCE C.-
Report Format and Content The staff shall prepare the SALP. report in general conformance to the guidelines in Exhibit 1.
V.
FINAL SALP REPORT sI)
A..
General The Regional Administrator.shall issue the final SALP report within 30 -
g SF days of receipt of the licensee's written comments or planned corrective actions. This= report'will receive the same distribution as the initial SALP report transmitted to the licensee prior to meeting with the licensee.
I
.B.
Final SALP Report l
z [if-the-iieensee--esponse-does-net-rescit-in-a-change-te-the-initisi
. report--er-if-the-iieensee-cheeses-not-to-respond--the-finai-SAtP-report transmittai-may-consist-ef;]- If,'after review of the licensee's written i
f response, the Regional Administrator determines that the information does not substantively alter the evaluation, or does not result in' a change to the initial report ~, or the licensee chose: not to respond, the final SALP report transmittal may consist of:
A summary of the meeting held with the licensee concerning the 1..
i (initial) SALP report.
A copy of the written response from the licensee (if any).
2.-
4 B-11 Approved: June 6, 1988
.'mm.
m
E.-
q, SYSTEMATIC ASSESSMENT OF.
NRC APPENDIX 0516
- j if,
LICENSEE PERFORMANCE 3.
The' transmittal letter, clearly referencing the date of issuance of.
b, the ' initial SALP report and a statement that the initial' report ise considered to be the final SALP repor-
[ T he-f i nai-S AtP-r e pe r t-mus t-normai i y-c o ns i s t-e f; ) If the licensee-i written response results in changes to the initial SALP report, then the final SALP report will consist of:
1.-
The initial SALP report with any changes made after the meeting with the licensee.
- 2. -
A summary of the meeting held with the licensee concerning the SALP report.
3.
A copy of the written comments received from the licensee.
4.
NRC's conclusion regarding the acceptability of the licensee's planned corrective actions, if required.
5.
The conclusions of the Regional Administrator based on consideration of the licensee's comments and planned corrective actions.
C..
Changing the Initial SALP Report Any changes made to the initial SALP report after the meeting with the licensee must be made using the following procedure (an example of each of the items mentioned below is shown in Exhibits 2, 3, and 4).
t B-12 Approved':
June 6, 1988
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' SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516f
^
LJCENSEEPERFORMANCE i
L1-tinclude a revision sheet (Exhib',t 2) as a separate enclosure to the Regional Administrator's cover letter denoting the change' and.the.
i basis for the change.
a 2.
Add tue revised page (Exhibit 4) to the report, leaving the original 4
page (Exhibit 3) in-the repor;.
3, Make a diagonal line through the original page, and reference the.
revision sheet.
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B-13 Approved:
June 6, 1988
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' SYS1TMATIC ASSESSMEST OF.
NRC Appenda 0516 L'
l
. IJCENSEE PERFORMANCE
}:/,J Table 2 EVALUATION MATRIX FOR OPERATING PHASE FUNCTIONAL AREAS -
4 1.
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11 I
a.
3 5
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} l Ia Plant Operations Radiological Controls Maintenance / Surveillance Ernergency Preparedness Securtty Engineering / Technical Support Safety Assessrnent/QualityVertfication
- Other
,o a
Approved: August 16,1989 A140
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' SYSTEMATIC ASSESSMENT OF ?
,NRC Appendix 0516 ~
UCENSEE PERFORMANCE.
-h Thble 3 -
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EVALUATION MATRIX FOR CONSTRUCTION 9
PHASE FUNCTIONAL AREAS.
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E-Soils and Foundations Containment, Major Structures, and Major Steel Supports Piping Systems and Supports
- Mechanical Components Auxiliary Systems Y
Electrical Equipment and Cables instrumentation l.
EngineeringrTechnical Support Safety Assessment / Quality Vertfication 1:
1.
Other Approved: August 16,1989 A1442 6'
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- SYSTEMATIC ~ ASSESSMENT'0F.
NRC' APPENDIX 0516
-LICENSEE PERFORMANCE EXHIBIT-1
[ INITIAL.'OR FINAL) SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION j
REGION [ number)
^'
It SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE I
L:
l (Inspection Report Number) l 1
l-D
[Name of. Licensee)
[Name of Facility and Docket Number) l;
[ Assessment Period)
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l B-16 Approvedi June 6, 1988 1.
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M-91 b#
' SYSTEMATIC ASSESSMENT OF NRC APPENDIX OSi6, l
LICENSEE-PERFORMANCE EXHIBIT 1 (continued)'
I.:
INTRODUCTION The' Systematic Assessment of Licensee Performance (SALP) program is ai.
integrated NRC' staff ef fort to collect available-observations and data on a periodic basis and to evaluate' licensee performance on the basis of this information. The program isl supplemental to normal regulatory processes used to enf ure compliance with NRC. rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis' for allocating NRC resources and to provide meaningful feedback to the licensee's man-agement regarding the NRC's assessment of their facility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met' on
[date), to review the observations and data on performance, and to assess licensee performance in accordance with Chapter NRC-0516, "Sys-tematic Assessment of Licensee Performance." [The guidance-and-evaination eriteria-are-summarized-in-Seetion-fil-ef-this-repert--The-Beard's-find-i ngs - and-re c omme ndati o ns-we re-f orwarded-to-the-NRE-Regi onal-Admi ni s tra-ter-for-approvai-and-issuance-)
This report is the NRC's assessL it of the licensee's safety performance at [name of facility) for the period [date] through [date).
s The SALP Board for (name of facility] was composed of:
B-17 Approved: June 6, 1988
~
]
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' SYSTEMATIC ASSESSMENT OF; LNRC APPENDIX 0516 LICENSEE PERFORMANCE-ji i
[ List SALP Board members' names and titles]
i 11.
SUMMARY
OF RESULTS j
.i A,
Overview i
i
[Previde-a-narrative-overview-summary-of-the-everali-effectiveness-of i i c e ns ee's-mana geme nt-i nci udi ng-ende riyi ng-s tre ngths-and-we akne s s e s:
This-summary-shecid-synthesize-information-en-iieensee performance-and identify-commen-themes-et-symptoms-ef-that performance--beth-within each-functionai-aree-and-across-fenetionai-areas -Biscuss performance j
trends--if-evident:-in-addition-provide-a-table-ef performance-ratings as-indicated-beiew:3
[The ratings assigned to individual functional-areas are only one aspect resulting from the=SALP process. The SALP Board is expected to assess each functional area in such a manner that the SALP Board discussion focuses on understanding the reasons for the observed performance. ' The attributes and assessment criteria provided in Appendix A should be used to develop a uniform and consistent approach.
After assessing all of the functional areas, the SALP Board is expected to discuss commonalities, if any-, among i
the functional areas. This process of reviewing the summary results from the standpoint of identifying common underlying reasons for the licensee's performance is the basis of the overview. The overview should also note functional areas where ratings have changed since the previous period and discuss'the reasons for such changes.
The overview should not be a summary statement of the numerical ratings of the individual functional B-18 Approved:
June 6, 1988
j
.. =
q SYSTEMATIC ~ ASSESSMENT.OF:
NRC APPENDIX 0516-
. LICENSEE PERFORMANCE Rather, the overview is intended to be'an executive summary with areas.
a synopsis of the underlying reasons, in the view of NRC managers, for both good and poor licensee performance as well as for chances in With regard to poor licensee performance, the overview-performance.
developed should be somewhat specific so that the licensee may be fully 1
aware of the areas in which increased utility management attention is required. ' The overview should also include any recommendations assigned In addition, provide a table of performance ratinas c
to functional areas.
as indicated below.
P i
I To emphasize topics for consideration beyond the specified functional y
o I
areas, NRR may identify selected topics for inclusion as part of the l'
overview.
Topics selected will be addressed by all SALP Boards for a j
defined period, and the summary results will be included as part of the overview.)
1 Eunctional area] [Ratino last period) [ Rating this period) [ Trend, if Any]
- l B.
Other Areas of Interest-
[ Provide an overview of licensee performance in each topic area. These topic areas are determined by the Director, NRR and/or the Regional Administrator.]
1 B-19 Approved:
June 6, 1988 i
03f.: r ir N
?
SYSTEMATIC ASSESSMENT OF NRC APPENDIX-0516~
i LICENSEE PERFORMANCE l
[EXHfBIT-1-feentinued))
o L
-fil:--ERfVERIA l-ticensee performance is-assessed-in-seieeted-functionai-areas--depending y
en-whether-the-f acility-is-in-a-construction-et-operationai phase:
r f uncti onai-are as-normaiiy-repres ent-are as-si gnificant-to-neelear-saf ety end-the-environment -Seme-functional-areas-may-not-be-assessed-because-of 1;
i i t ti e-o r-no-i i e e ns e e-a cti vi ti e s-et-i a c k-of-me ani ngf ei-ob s e r v a ti o n s :
1 Spe ci ai-are as - may-be-a dde d-t o - hi ghl i ght-s i gni f i c ant-eb s e rv ati ons :
i T he - f eii ewi ng-ev ai enti on-eri te ri a-we re-us e d-- as - appii enbi e-- to-as s e s s each-fenetionai-area; li l
17---Assurance-of quaiity--incinding-management-inveivement-and-centrol; i
i l'
l-2:--- Approach-to-the-re sci uti e n-of-te chni cai -i s s ue s -f rom-a- s af ety j
standpeint-
-l
. B:--- Re s ponsi v e nes s-to-NRE-i ni ti ati v e s-1 l
l' 4 ---Enforcement-history; h
5:--- Op e rati o nai -and-c o ns truc ti en-ev e nts -(i nei ndi ng-re s p ons e-te-- analys e s ef--reperting-of--and-corrective-actions-for) '
6---- Staf f i n (i nei ndi ng-manageme nt31 - and B-20 Approved: June 6, 1988 i'
l
n.
-SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516' s
LICENSEE PERFORMANCE 1
EXHIBIT 1 (continued) l l
7;--- Ef f ecti vene s s - of-trai ni ng-and-quali fi cati on-program:
u Howev e r-- the-NRE-i s - net-i i mi te d-to-the s e-eri teri e-and-othe rs - may-ha ve.
been-used-where-appropriate:
O n-the-ba si s-of-the-NRE-as s e s sme nt-- e ach-f ane ti o nai-a re a-e v al uate d-i s rated-according-te-three performance-eategories -The-definitions-of-these j-perfermance-eategories-are-as-feiiews; 1; --- E s t e ce ry-1;- ti c e ns e e-mana geme nt-att e nti o n-a nd-i nv oi y eme nt-a r e reediiy-evident-and piace emphasis-en-superier-perfermance-ef-no-
[
ciear-safety-or-safegeerds-activ4 ties--with-the-resuiting perform-ance-substantially-exceeding-regulatory-requirements:-ticensee re s entee s-are-empi e-and-e f f e cti v ely-us e d-s e-that-a- hi gh-i ev e i - o f piant-and personnei-performance-is-being-achieved:-Redeced-NRB j
attention-may-be-approprister L
2 ---Eatecery-fr-ticensee-management-attention-to-and-inveivement-in-the performance-of-neciear-safety-or-safeguards-activities-is good:-The iicensee-has-attained-a-ievei-ef performance-above-that-needed-te
\\*
I meet-regui story-requirements:-ticensee-resources-are-adequate-and.
reasonabiy-eileested-se-that good piant-and personnei performance-is p.*
b e i n g-a c hi e v e d:- N R E-a tt e nti o n-may-b e-mai nt ai ne d-at-ne rmai-i e v ei s
/
B-21 Approved':
June 6, 1988 c
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-SYSTEMATIC-ASSESSMENT OFL NRC APPENDIX 0516 i
7Fik
- LICENSEE PERFORMANCE-U.
s EXHIBIT 1 (continued)-
i f'
' B ---Eatenery-3:-ticensee-management-attention-to-and-inveivement-in-the LE J
. pe rf ormance-of - naci e ar-s af ety-o r-s af e g ua rds-a c ti v i ti e s - are-net D sufficient:-The-licensee's performance-dees-net-significantiy-exceed L
that-needed-to-mee t-mi ni mei-regul atory-re qui reme nts :- ti c e ns e e.
re s entee s-appe ar-to-be-strai ne d-e t-not-e f f ecti v ei y-us ed:- NRE-atte n-ti on-s heni d-be-i nc re as e d-abov e-ne rmai-i e v ei s
- a.
9
[iV]III. PERFORMANCE ANALYSIS t
[ State functional area being discussed] [ Number of inspection-hours A.
- l expended in this functional area, and as a percent of total'inspec-
~
i tionhours) l 1.
Analysis
[This analysis should concentrate on the adequacy of the licensee's management control systems and assurance of quality, f training
. personnel performance and staffing, effectiveness o i
and qualification program, enforcement history, and the degree to which the licensee is committed to superior performance. This t
section should not necessarily reiterate or tabulate the information and data that contribute to the analysis. Rather, it The analysis should be a summary of the supporting rationale.
should be concise yet fully communicate the NRC assessment of licensee performance. The length of each functional area e
B-22 Approvedi June 6, 1988 k
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- SYSTEMATIC ASSESSMENT OF
't NRC APPENDIX 0516.
&~. f, LICENSEE PERFORMANCE-m 1 analysis should reflect'the applicable NRC resources expended F --'
and'11censee activities durina the ' assessment period. Any appropriate [i)-information and. data should~ be provided in Section [V)IV of this report, Licensee' performance should be j
discussed in light'of the evaluation. criteria and associated -
e at.
i attributes both to ensure completeness and to compare licensee
.j performance across functional areas. The analysis is intended to j
besufficiently; diagnostic.toprovidearationaleforallocating
'NRC resources and te ;,Fvvide meaningful guidance to licensee's management.)
- 2.
Performance Rating
'l i'
[ Provide the performance rating.(Category 1, 2, 3, U or N [er-3])-
for each functional area considered. If-appropriate, include:a
~
trend assessment (improving or declining).[--charseterizing iieensee performance-near-the-ciese-of-the-assessment peried-]
i 3.
Recommendations ll
.[ Include any general or specific NRC recommendations pertaining to either licensee management's attention or the level of NRC inspection activities in a functional area. Note umi ri:r in
'the absence of a recommendation to vary the inspection effort, the Regional Office may do so at its discretion on the basis of appropriate NRC Manual chapters.]
i B-23 Approved':
June 6, 1988 9e
4
]
o SYSTEMATIC ASSESSMENT Of NRC APPENDIX 0516 LICENSEE PERr0RMANCE i
[V)IV.
SUPPORTING DATA AND $UMMARIES 1
.A.
Major Licensee Activities
[ Provide a factual outline of major licensee activities, such as j
major outages, power limitations, important license amendments,. and l
significant modifications.)
1 B.
Major Direct Inspection and Review Activitiec I
t J
[ Provide a factual summary of major direct inspection and rex!ew activities performed by resident inspectors, Region-based staff, and j
Headquarters staff in each functional area. This is not intended to l
bu a summary of each inspection or review performed, but rather of those that had a significant effect on the 'results discussed in Section 111 ly of this report.]
[E;--Enfertement-Activity)
[incinde-Tabie-h.uinf orcement-Activity...,,.f eetnetes-to-identify u
any-f enc ti onai-areas - as s eei s te d-wi th-ci vi i - pe nsi ti e s-er-orde rs: )
B ---Eenfirmatien-ef-Actien-tetters
[ Provide-a-summary ]
t B-24 Approved: June 6, 1988
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$YSTEMATIC ASSES $ MENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 (f)C. Other N
[ Discuss any other issues or additional supportina information at the discretion of the SALP Board.]
=
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B-25 Approved:
June 6,1988
,z
SYSTEMATIC ASSESSMENT OF
.t1CENSEE PERFORMANCE NRC APPENDIX 0516 EMHIBli 1-(continued)
TABLE-1 ENFOREEMENT-AETIVITY FWNEii6NAt----------------- -------N6;-6F-Vi6tATf 9NS-IN-SEVERITY-tEVEt AREA--- ------------------------Y---------IV--------lil-------II--------I 16TAL Feetnotest B-26 Approvedi June 6, 1988
a.
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101 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516
]
EXHIBIT 2
-l i
REVISION SHEET l
i l
SALP BOARD REPORT REVISION SHEET PAGE LINE NOW READS SHOULO READ 5
24 operator's coonitive decision operator's decision
)
Basis:
The word " cognitive" was deleted to avoid further problems in inter-l preting its meaning. As used, the word was intended to mean that the operator, as the cognizant individual on shift, knew the operating requirements of the Technical Specification but made a conscious decision to operate the plant in c
a manner which he/she believed was equivalent to the requirements.
It was not intended to mean that the operator took actions in total disregard of'the Technical Specification objectives.
?
1 t
t B-27 Approved':
June 6, 1988
~
s
. r, SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC AppendLv 0516 EXNIBIT 3 ORIGINAL PAGE i
b!P mums
- verity Level IV
- Failure to take lleety and proper corrective
- ien following the fa(Ivre of a seid leg EfD (SP900/41*24).
i 8ty Level V1
- FaiIvre 4e make a 30 day esport on a degraded tese relay (SP D00/81 26).
Sia ip1(antes were'for failure to othe required reports er erts, feve for failure to follow proteivres, and one to es.
for int, watetten. One montespitance for failvre to properly i
i Ites (9) above is part of an estoisted 9tainment report a s Civil denalty. The sabel event, to destr16ed enforteme n, in Section n
- e.
Nine LtA's re16
- tree were tavsed by personnel errers, sis st Unit 1 and thi Staty percent of these etterred in the Isot half of the p.
'rty percent in the last guerter indigsta j
in the perted. 81s of the nine were j
ing an intreestap et k *'gnments and three were for failure to for intetMst va ve es follow operating proces, g
Two events (Ltt's 50 000/.
e,.
- g %D00/81 St) were
. particular sentern since they Mflette6 '.',
4er itive decision to
.,erate..xste. (thergi,
. g' ' g>..ator s tegn
..ntaineent <seisuen, respettively) in a manner not a
' Technical Specif ttations.
4 Unit 1 experiented nine evtone' tic 4
the evaivation perted, fevr caused by operator error and t h tent fatture. Of the four sevsed by errors, two were due $4 toMutted instenment surveillance tests, one to en interrect
- en the steam side, aM the last te unfamiliarity with tort 16.
- Watt i experiented nine oestter trips, one.
- 11y initiated tureine trip. Feve of the trips were related errors; two
- low steen by less of vetum in the sain sondenser, one re.
generator level, eW ene tuvited free a tuttfA Signment.
We sientf tcent safety sentern is essettsted with tk 4 eeth was Mytowed te verify proper oefety system operet.
Stor actions.
Verlevs operating probless and events identified during resulted in en enforcement meeting on August 4,1941, erit.
eetting on August 4,1981, with followup esednes en tedet s
)
Approved: August 16, 1989
..?
i SYSTDtATIC A8888'8 MENT OF o
NRC Appendia 0616 LICENSEE M EXHIBIT 4 i
1 4
(10) Severity Level IV Fatim se late steely and proper eeWortive I
action fellering the failure of a sold leg 270 (or000/8134).
(11) Severt LevelVI*FativMtoasksa80dayrephet'enadesteded bus to tape teley (Sp 000/ttd28).
Sia of the noncomp1tances were for failure to este required reports or to make timely reports. fove for fa11ere to follow procedures and one for incomplete detenentatten. One monteep1tente for fattere b property report a breach in tentsinment Ites (3)The actual event, is Gestribedabove, is p enforcementettfenwithCiv11denalty.-
in Settien 4. Surveillante.
kine Ltt's relating to this erse wee sovsed by ponennel errors, sia et' Unit 3 and three at Unit 3.
Staty pement of these estvered in the last half of the perted and thirty pement in the last everter indicating on increasing etterrence rate te the perled. Sta of the nine were for incorrect valve er breaker attgments and three wem for failure to fellev sperating precedores.
Two events (Ltt's 60 000/8187 and 60 000/8182) wers of partitular L
(
sentern sface they reflected a licenses operator's desisten to operate a
's eenne(t est allovei by the feshaltal SpeeifIsations.thert as and letfevn a erstes f
i l
Unit 3 esperienced nine automatit trips during the evolvetten perled.
feve-taused by operator etter and five by enviament fatture. Of the feve sovsed by errors, the were eve to interrottly sendveted instrument survet11snee tests one to en interrett talve Ifneup en the staas side, and the last te unfamilferity with tuttine sentrols.
l.
Unit i esperienced nine teetter trips, one 'being e manually inttleted -
tur6tne trip. Feve of the trips won related to personnel errorst two by less of watuus in the main tendenser, one resulted free a lov steen i;
. generator level, and one resulted free a turbine talve eiseitgeent.
he signifftent safety concern is essettsted with these trips and each was revie d to terify pr.per.efety system operation.w openter
.tsien..
Verfens operating problems and events identified during the period eesting on Avevst d.1983 with followup meeting.1983 with fellevue tesulted in en enfomosent setting on August 4 i
s en Nevenber 2.1981
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Approved: August 16, 1989 3
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.