ML20091S053

Comment on Review of Revised NRC SALP Program.Use of Numerical Scores Has Proven to Be Punitive from Economic Perspective

ML20091S053
Person / Time
Site:	Crystal River
Issue date:	08/31/1995
From:	Kelley L FLORIDA POWER CORP.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR39193, RULE-PR-50 60FR39193-00016, 60FR39193-16, NL95-0079, NL95-79, NUDOCS 9509070269
Download: ML20091S053 (5)

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l August 31, 1995 NL95-00 79 - 1 l

U. S. Nuclear Regulatory Commission

. Attention: David Meyers, Chief, Rules Review and Directives Branch Division of Freedom of Information and Publication Services Office of Administration, Mail Stop T-6D-59.

Washington, D. C. 20555

Subject:

Review oi Revised NRC Systematic Assessment of Licensee Performance (SALP) Program )

Dear Sir:

l The Federal Register, Vol. 60, No.147 dated August 1,1995, requested comments from the regulated industry concerning the revised NRC Systematic i Assessment of Licensee Performance (SALP) Program and its implementation.

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Florida Power Corporation provides the attached as our comments.

l Sincerely,  !

L. C. , Director Nuclear Site Support

, LCK/RLM:ff Attachment J

CRYSTAL IWER ENERGY COMPLEX: 15700 W Power Une St . Crystal FWver, Florida 344284708 e (904) 7954486 A Florida Progress Company $

9509070269 950831 ~

l PDR ADOCK 05000302 0 pop s

D A. Functional Areas 4

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QUESTION: COMMENT

, 1) Are the current four functional areas Somewhat. It does provide a more even j (operations, maintenance. engineering,and weighing. Previously, less safety

plant support) an improvement compared to significant areas received a separate, ,

the previcus seven functional areas? equivalent rating. However,it has become )

! too generalized for use by the licensee. 1 I

l i 2) Are the plant support functional . Generally, yes. However, concerns in some area messages clear in characterizing areas are inappropriately lumped together.

2 individual elements (radiological controls, emergency preparedness,-

j security, fire protection, chemistry housekeeping?

j 3) Are additional improvements needed for No comment.

l the designation of functional areas? What

! types of improvements?

d 3

, B. Management Involvement

! QUESTION: COMMENT

{ 1) Did increased NRC management No. The report still seems very

involvement in~the SALP program result in subjective. Feedback during the public

program improvements and improved meeting to present the SALP seems to be communication with licensee management? missing. Too often board members only i come to the site once right before the end I of the SALP period. This is inadequate to j gain a full perspective of performance.

4 2) Did the SALP program changes result in No. The report still seems very 1 better licensee and public understanding subjective and based on little first hand 1 of the SALP results? knowledge of the SALP board members. The j site visits by the board members seem to

j. always occur just prior to the end of the

period and seem to gather information only to support pre-conceived conclusions. The

, shorter report made for easier correlation between rating and written examples;

' however, the report does not reflect the significant volume of information that

, really supported the rating. The public only sees what is in the report and only-looks at the average scores. Note comment in Section E on numerical scores.

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x 13).Did increased' involvement of'the' There seems to.be relatively smal1~

regional administrator or deputy at'the improvement. This is not meant to ,

2 SALP_ meeting result in-improved criticize the. administrator or his deputy. 1

- communication with licensee management? The presentations are just not that-  !

).

differeno.  ;

. 4) Was the change in'SALP presentation Although it.has the appearance'of a'two i meeting format from'a presentation to more way discussion, listening and unbiased-

, of a discussion effective in improving: consideration of what the other party is ]

communication with. licensee management? saying~ still appears one way. As long as the meeting is a public meeting full, 1

) candid discussion will be inhibited. l t

5)LAre' additional; improvements needed in More feedback between SALPs is needed, hui  :

the areas of communications with licensee this must be based.on first. hand knowledge ,

managementiand licensee and public .

by periodic visits by NRC management at ]

higher levels.

understanding of SALP results? What types 4 of improvements?.

3 There also needs to.be more routine continuing communication throughout the.

SALP period.

C. Assessment Period 4

QUESTION: COMMENT t-

1) What bases should be considered when With good communication SALP is really a i'

determining SALP period length and how formality; therefore the period really 7

should they be applied? doesn't need to vary. Issuing SAI.P on 2 _

[ year basis for everyone would seem j appropriate.

i

2) SALP assessments currently range from No. Some of the most notable falls in

' 12 to 24 months (nominally 18 month performance (although rare) would be those i average). Is this variation in practice a at the top that became complacent and  ;

appropriate? which went unnoticed for too long. Also, l Wall Street ratings put unwarranted merit l i on these differences.

3) How long should the SALP assessment SALP periods should be the same - 24 period be for good, average, and poor months with 3 to 6 month interim updates ,

performing plants?

between NRC and plant management. i 3-a  ;

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D. Salp Report QUESTION: COMMENT __

1) Are the new, shorter SALP reports more No. The structure of INPO reports is a effective in communicating the results of better format. This lists criteria for the NRC's assessment of safety performance performance measurements first then then the previous, more lengthy reports? follows with strengths and areas for improvements.

2) Are SALP reports appropriately focused Not always. The reports sometimes focus a on safety issues and do they deliver a significant amount of attention on non-clear message? safety significant issues and cross into l utility management practices / I personalities. The reports are based primarily on a review of correspondence between the NRC and licensees, which is by nature primarily dealing with negative aspects of operation. l l

3) Do SALP reports provide a balanced No. By their nature, SALP reports l accentuate the negative in the majority of assessment of licensee performance (and are positive aspects of licensee safety cases often using adjectives to embellish performance appropriately considered)? the descriptions drawn from subjective conclusions rather than just presenting the factual evidence or events.

4) Do SALP reports consistently focus on There are notable exceptions indicating the last six months of performance? Is the reports do not focus on the last six this practice appropriate? months. Bias from even years before tend to influence judgements especially in those who do not visit the sites.

Yes, it is appropriate.

5) Is the level of detail in the SALP Yes, but only if you are familiar with the report appropriate? underlying basis. The report needs more information on how the board views related events, e.g. trend or unique.

6) Are SALP report conclusions well Generally yes, but factual support for supported by documented facts? SALP report conclusions is inconsistent.

There is so much data available, any conclusion could be supported depending on which data was chosen to be documented.

7) Are SALP report cover letter messages Cover letter messages are usually consistent with the associated SALP report consistent but are often incomplete or messages? represent a partial view.

8). Are licensee self-assessment efforts The level of NRC recognition of self- I adequately recognized in the SALP report. assessments is disappointing, especially and cover letter? in team inspections. Further, it seems the NRC still penalizes self-identified findings which tends to discourage the continued use of extensive self- )

assessments. l

9) Are additional improvements needed in See response to D.I. above. INP0 the SALP reports? What types of specifies the criteria first and then improvements? assures their comment supports a measure of how the criteria was met or not met based on factual observation.

E. Other Comments The use of numerical scores has proven to be punitive particularly from an economic perspective. Because of this, the tendancy is to focus on the rating instead of the substance of the report. It seems a process without scores that evaluates and assesses  !

areas as doing well or needing improvement would be a more effective approach.  !

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