ML20091Q271

Comment Opposing Review of Revised NRC SALP

ML20091Q271
Person / Time
Site:	Farley
Issue date:	08/28/1995
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-60FR39193, RULE-PR-50 60FR39193-00005, 60FR39193-5, NUDOCS 9509050278
Download: ML20091Q271 (2)

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J*J f Southern Nuclear Oper; ting Company .

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Dave Morey

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$n ou'tifefd NL c7da}Dperatine r v Company Vice President h-s L L L iL i .L . ,. a. . E,itthe southem electnc system Farley Project August 28, 1995 U5h;iC Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 7

Comments on

" Review of Revised NRC Systematic Assessment of Licensee Performance (SALP) Program" (60 Federal Register 39193 dated August 1.1995)

Dear Sir; Southern Nuclear Operating Company (Southern Nuclear) has reviewed the request fer public comment ." Review of Revised NF.C Systematic Assessment of Licensee Performance (SALP) Program," published in the Federal Register on August 1,1995.

In accordance with this request, Southern Nuclear has provided general comments as an attachment to this letter.

Respectfully submitted,

@ W V V Dave Morey DNM/JMG Attachment cc: Southern Nuclear Oneratine Comnany

                                    .R. D. Hill, Plant Manager :

U. S. Nuclear Regulatory Commission. Washingtan. DC l B. L. Siegel, Licensing Project Manager, NRR l 1: U. S. NuckaiReculatory Commission. Recion II i S. D. Ebneter, Regional Administrator. , T. .M. Ross, Senior Resident Inspector j

                                                                                                                                        .1 9509050278 950828 "

PDR ADOCK 05000348 0 PDR (i 1

1 .; I Attachment Comments on

                                         " Review of Revised NRC Systematic Assessment of Licensee Performance (S ALP) Program" The S ALP program was initially established to prioritize and focus NRC inspection resources. Since the program was established, the SALP has been used for significantly different purposes. Although the four functional areas which are currently being used are an improvement in comparison to the previous seven functional areas, this program has been used to exert pressure on licensees to comply with NRC staff demands and expectations beyond those required by the regulations. The SALP serves as an informal mechanism for the NRC staff to bypass the formal rer alatory process.

The standards which are set by the SALP are based on subjective determinations that are outside the framework of the NRC regulations. The SALP ratings of 1,2, or 3 are levels of performance that are in complete compliance with the NRC regulations; however, a licensee that receives a SALP 3 rating is viewed as a poor performer. This rating level results in negative impacts that span the financial community as well as the NRC and the public. Although not intentionally, the SALP provides the NRC staff with tremendous leverage over the licensee which far exceeds the intent of the regulatory authority. The Regulatory Impact Survey performed by the NRC in 1989 concluded that licensees acquiesced to inappropriate regulatory demands in order to avoid poor SALP ratings, and, consequently, poor financial ratings. This results in the SALP process inappropriately involving the NRC staffin the daily utility management decision-making process. The SALP process establishes grades based on opinion rather than on established and consistent criteria. The resulting " moving target" for utilities pushes licensees beyond the scope of existing, formal regulations. The NRC staff and Commission should, again, reevaluate the fundamental elements of the SALP and strongly consider discontinuing the SALP program. Other process are in place, such as the NRC's new Integrated Performance Assessment Program (IPAP), to more accurately portray a balanced view oflicensee performance. l _}}