ML20094M796
| ML20094M796 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/13/1984 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX20-035, CON-BX20-35, FOIA-84-96 NUDOCS 8408150728 | |
| Download: ML20094M796 (2) | |
Text
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NUCLEAR REGULATORY COMMISSION y
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OLsN su.YN, ILUNolt 00137 APR1 3 E4
., MEMORANDUM FOR: Region III Management and Technical Staff FROM:
Charles E. Norelius, Director, Division of Project and Resident Programs
SUBJECT:
REVISION TO MC 0516 - SYSTEMATIC ASSESSMENT OF LICENSEEPERFORMANCE(SALP)
Attached is an advance copy of the proposed revision to NRC Manual Chapter 0516. Systematic Assessment of Licensee Performance, for your I
review.
i As requested in Mr. DeYoung's memorandum of March 12, 1984, we plan to implement this procedure immediately and will follow the new guidelines beginning with the Clinton SALP Report which is now in preparation at the l
Resident Office.
l While the significant changes to the new procedure are highlighted by darkened lines in the right margin I would like to sunnarize a few of the l
administrative changes which have been incorporated into the procedure which differ from those previously followed.
i 1.
The format for SALP inputs has not been modifief., but expanded to include submittal of an Evaluation Matrix which will serve to provide background in sstablishing an overall performance rating.
2.
Issuance of a Preliminary SALP Report will no longer be required.
l The SALP Board Report, upon approval of the SALP Board, will be i
issued as FINAL and forwarded to the licensee.
3.
You will note in the revised procedure that meetings with the licensee are no longer a requirement but are left to the discretion of the Regional Administrator or held specifically at the request of licensees. We plan to continue, however, to normally hold meetings with licensee management, as we have in the past.
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I3 b Region III Management & Technical Staff 4.
Included in-the transmittal letter enclosing the SALP Boerd Report is a paragraph ^ formally requesting that the licensee proiiide written comments on the SALP Board Report and the NRC findings in'cluded therein.
5.
Once the report is issued to the licensee, the procedure to be followed for making significant corrections to the report becomes more involved than in past practice.
While the Errata Sheet continues as the primary means for making corrections to the report, a narrative basis is now to be included on the Errata Sheet to further explain the necessity for each correction made. A corrected page must then be prepared incorporating the changes, the original page included but lined-through referencing the Errata Sheet and all pages assembled for transmittal to the licensee as an attachment to the Appendix Package from the Regional Administrator.
(TheAppendixPackageisdefinedinItem6.)
6.
The final stage of the SALP process involves the transmittal of corrections made to the report, if appro the.SALP Board Report which includes (a)priate, and an Appendix to a summarization of the meeting which was held with the licensee to discuss the report.
(b) the verbatim written connents received from the licensee, and (c) presentation of all the conclusions reached by the Regional Administrator after thorough review of any such connents.
These changes, as well as others of a technical nature not discussed herein, will be covered fonnally in a Regional Procedure currently being prepared by the Technical Support Staff.
g46Y MM Charles E. Nore11us Director Division of Project and Resident Programs j
Attachment:
Revised SALP Procedure h
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'q, UNITED STATES y, y.,.. f NUCLEAR REGULATORY COMMISSION a
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March 12, 1984 i
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MEMORANDUM FOR: Those on Attached List qp File i
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FROM:
Richard C. DeYoung, Director Office of Inspection and Enforc,eme,nt
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SUBJECT:
PROPOSED REVISION TO NRC 0516 (SALP PROGRAM)
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Con =ct.ts on the proposed revision to NRC 0516, Systematic Assessment of Licensee Perfomance (SALP), have been ' received. provides a sum:r.ary of the changes c:ade based on the comments received.
provides a copy of NRC 0516 with the specific changes made. Significant changes are indicated by lines in the right hand margin.
The enclosed procedure is being submitted to the Director, Office of Resource Management, for final review and-approval and is being forwarded to you 'as an advance copy. We believe the revision to NRC 0516 represents a significant improvement to the program, including some changes already in effect, and we are anxious to expedite femal issuance of the revised program. #4ptgKr,
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Richard C,
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.ector Office of 1.p4pection and Enforcement
Enclosures:
1.
Resolution of Connents to the Proposed Revision toNRC0516(SALPProgram) 2.
HRC 0516 (changes marked)
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Contact:
James P. Kearney (492-9669)
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1 Steven D. Richardson (492-9612)
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Multiple Addressees 2-Victor Stello, Deputy Executive Director for Regional Operations and Generic Requirements t
Office of the Executive Director for Operations Harold R. Denton, Director Office of Nuclear Reactor Regulation John G. Davis, Director Office of Nuclear Material Safety and Safeguardt Clemens J. Heltemes, Director Office for Analysis and Evaluation of Operational Data Thomas E. Murley, Regional Administrator, Region I Jares P. O'Reilly, Regional Administrator,. Region II
-Cames G. Keppler, Regional Administrator, Region III John T. Collins, Regional Administrator, Region IV John B. Martin, Regional. Administrator, Regio'n V e
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Resolution of Coments to the Proposed Revision to NRC 0516 (SALP Prooram) 1.
Coment.
Regions II and IV were opposed to conducting the SALP manage-ment meetings as open meetings.
2 Resolution. No change was made to the proposed program, iihich reflects cecision of EDO as discussed in the previous Management Meeting.
2.
Coment.
Regions I, II, and III were opposed to having the Regional Administrator transmit the SALP Board Report to the licensee. The recomended alternative by the regions was to structure the SALP process to allow the lic'ensee to respond to the report.before the' assessment results are made final.
(ie.* keep it the way it has been).
Resolution. No change was made to the proposed program, which reflects oecision of EDO as discussed in previous Management Meeting.
3.
Coment.
Regions II, III, and IV, and AEOD were opposed to the Table format proposed in Part VII Exhibit 2, for documenting LER information.
Resolution. Changed the format of the Table used for documenting LER information.
4.
Coment.
Each Region fett the guidance provided on the timelines:
of SALP Board Mee. tings and meetings with the ' licensee were too restrictive.
. Resolution. Modified the guidance given for meetings with the licensee to 90 days to allow sufficient time for public notification of the meeting.
5.
Cc=ent.
Regi.ons I, III, and the ED0's office recommended that Table I (Evaluation Criteria) be modified.
Resolution. This was outside the scope of the proposed change.
It is recomended that a task force, composed of a represer.tative of each Region, IE, AEOD, and NRR, review the evaluation criteria for future changes in the SALP process.
6.
Coment.
Each Region had spec'ific come'nts on the functional area definitions.
- f, Resolution. The functional area definitions were modified to incorporate the majority of the specific coments.
'J.
Coment.
NMSS wanted to include fuel facilities in the SALP -
process.
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Resolution. No change was made to the proposed program tEause' the budget will not support, the manpower required.
8.
Coment.' Region'I! opposed the composition of the SALP Board.
Specifically, the inclusion of non-management persons on the Boa rd.
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Resolution. No change was made to the proposed prcgram.
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NRC MANUAL i
Volume:
0000 General A inistration-Part:
0500 Health and Safetf IE CHAPTER 0516 SYSTEMATIC ASSESSMENT OF LICENSEE. PERFORMANCE
- 4 0516-01 COVERAGE This Chapter and its appendix describe the basic structure and overall precedures for implementation of the NRC program to assess licensee perfcrm-ance. This program applies to all power reactors with operating licenses or.
construction permits (hereinaf.ter referred to as licensees).
0516-02 OBJECTIVES j
021 To improve the NRC regulatory program.
022 To per:r.it sound decisions regarding NRC resource allocations.
, 023 To improve licensee perfomance.
j 024 To collect available observations on a periodic basis and evaluate l
licensee performance based on those observations, through the Systematic Assessment of Licensee Performance (SALP), an integrated NRC staff effort.
Fositive and negative attributes of licepsee performance are considered.
Emphasis is placed upon understanding the reasons for licensee's perfom-
. ance in important functional areas,,,a,nd sharing thir understanding with the licensee. The SALP process is orfanted toward furthering NRC's under-i standir.g of the manner in which:
(a)thelicenseemanagementdirects, j
guides, and provides resources for assuring plant safety; and (b) such
- ~
. resources are used and applied. The integrated SALP assessment is intended to be sufficiently d.iagnostic to provide a rational basis for allocating HRC resources to provide meaningful guidance to licensee sanagement.
051,6-03 RESPONSIBILITIES'AND AUTHORITIES t
031 The Executive Director for Operations (ED0).
Provides oversight for the activities described herein.
Approved:
. n :..0 SYSTEMATIC ASSESSMENT DF 0516-032 LICENSEE PERFORMANCE
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032 The Director Office of Inspection and Enforcement (IE):
4 Implements the requirements of this. chapter within the Office "
a.
of Inspection and Enforcement.
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Monitors the SALP process; evaluates and develoIIs SALP policy, b.
criteria, and methodology; and assesses the uniformity and adequacy of the regions' implementation of the program.
033 The Directors.-Offices of Nuclear Reactor Regulation (NRR).
l Analysis and Evaluation of Operational Data LAE00), and Nuclear i
Materials Safety and Safeguards (NM.95).
Imp ement the require-t.
ments of this chapter within their Offices.
034 Recional Administrators I
Implements the iequirements of this chapter within the a.
Regi.ons.
b.
Ensures that assessments of licensee nuclear safety perfor'-
mance are conducted.
l Determines when-a meeting with the licensee is necessary to c.
assure mutual understanding of the issues discussed in the SALP Board report.
i d.
Evaluates tFe SALP Board report and the licensee's coments; crevides a characterization of overall safety performance; i
GstrmallyissuestheNRC5ALPrepoRt:followsuponlicensee l#
commitments; and reallocates region inspection rescurces as appropriate.
3 1
e.
Provides to the Director, Office of Inh 1Tction and Enforce-
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ment, recomendations for improvements to the SALP program e.
I and coments on proposed changes to SALP polip 0516-04 EVALUATIONCRITERIAANDFUNCTIONAL)REAS j
041 Evaltiation.
Licensees will be Y aluated in the functional areas i
listed in section 042 using the criteria provided herein and further amplified in the Appendix to this Chapter. Each func-tional area evaluated will be assigned & Category as defined in Section 043 and a performance trend as defined in Section 044.
Not all functional areas need be covered in a given ritView..If a functional area appropriate to a licensee is not cpered, the reasons should be given in the report. The Appendix-to this Chapter lists a number of attributes for each evaluation criterion.
The functional area being evaluated may have some attributes that would place the evaluation in Category 1 and others that would place it in either Category 2 or 3.
The final rating for each funct'ional area wC1 be a composite of the attributes tempered with judgment as to significance of individual items. Departures
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. SYSTEMATIC ~ ASSESSMENT 0F LICENSEE PERFORMANCE 0516-041 s-from this guidance may sometimes be warranted.
In such cases, i
the rationale for such departures should be explained in the report.
s 042 Functional Areas. A grouping of similar :ct"ities.9,~
i a.
Operating Phase Reactors 1.
Plarit Operations Consists cliiefly of the activities of the licensee's operational staff (e.g., tiensed operators, shift technical advisors, and auxiliary operators).
It is intended to be limited to. operating. activities such as.
plant startup, powet operation, plant shutdown, and s.
i Gystem uneeps; Thus, it includes activities such as reading anc logging plant conditions; responding to off-normal conditions; manipulating the reactor and auxiliary controls; and training / retraining of licensed operators, shift technical advisors, and auxiliary operators.
2.
Radiolocical Controls j
Iticludes control.s for occupational radiation protection; radioactive materials and contamination controls; radiological surveys and monitoring; processing of gas-eous, liquid, and solid wastes; transportation of radioactive materials; radioloc_ical effluent ancf environmental monitoring;fand 'the results of the fiRC's7 Qndependent measurement, program.f 3.
Maintenance
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Includes all activities n'ssociated with preventive or corrective maintenance of instrumentation and control equipment and mechanical.and electrical systems.
.s 4.
Surveillance
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Includes all surveillance testing activities as well as all inservice inspection and testing activities.
L.
Examples of activities included are:
instNment cali-brations, equipment operability tests, cen.tainment leak l
rate tests, special tests, inservice inspection and performance tests of pu ps and valves, and-all other i
inservice inspection activities.
i 5.
Fire Protection Includes routine housekeeping and fire protection /
prevention program activities. Thus, it includes the i
storage of combustible material; fire brigade staffing e
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. - SYSTEMATIC ASSESSMENT OF 0516-042a5 LICENSEE PERFORMANCE and training; fire suppression system maintenance and operation; and those fire protection features provided for structures, systems, and components impcrtant to safe shutdown.
c 6.
. Includes activities relating to the implementation of the emergency plan and implementing procedures. Thus, it includes such activities as licensee's performance during eiercises which test the licensee, state, a'nd local emergency plans; plan administration and implemen-tation; notification; communications; facilities and equipment; staffing; training; assessment; emergency classification; med'ical treatment; radiological exposure control; recovery; protective actions; and interfaces with ensite and offsite emergency response organizations.
7.
Security Includes all activities whose purpose is to ensure the security and continued operability of the plant.
Specifica1.ly it includes all aspects of the licensee's security program (e.g. access control, security checks.
badging).
8.
Refuelinc
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Includes all activities associated with refueling.
Thus, it includes outage mana
, lation of new and spent fuel.gement, and the nanipu-9.
Quality programs and Administrative Controls Affecting Ouality Includes all verification and oversight activities which affect or assure the qual.ity of plant activities, structures, systems and components. This area may be viewed as a comprehensivf management system for con-quality of verification,' activities that confirm thattrolling the work was performed correctly.
The evalpation of L-the effectiveness of the quality assurance system should be based on the results of managemen$ actions
' l-to ensure that necessary people, procedureri facilities and materials are provided and used during.(he opera-tion of the nuclear power plant.
Principal-snphasis should be given to evaluating the effectiveness and involvement of management in establishing and assuring the effe'ctive implementation of the quality assurance program along with evaltating the history of licensee performance.in the key areas of:
committee activities, design and procurement control, control of design j
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. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-04.2a9 change processes, inspections, audits, iiorrective action systems, and records.
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- 10. Licensing Activities f'*
Includes the adequacy and ticeliness of a.11 licensing submittals, responsiveness to NRC licensing initiatives, and the licensee's approach to resolution of technical issuis from a safety standpoint.
- 11. Others (As Needed) s b.
Construction Phase Reactors 1.
Soils and Foundation Includes afl soil and foundation activities related to the construction of the ultimate heat sink and safety-related structures. Specifically, this covers, as applicable, subgrade investigation and preparation, fill materials and compaction, e.bankments, foundations and associated laboratory testing, instrumentation and
. monitoring-systems.
2.
Containment. Safety-Related Structures, and Mahr Steel 5uooorts Includes all activities related to the structural concrete and steel used in the containment (including the basemat) and safety-related structures, and major steel equipment supports.
It includes all aspects of structural concrete (e.g., reinforc3g steel; concrete batching, delivery, placement, in-process testing, and curing; liner plate erection and fabrication; and con-tainment post-tensioning), structural steel used in safety-related structures (welded and bolted), and major steel equipment supports (for reactor vessel, reactor coolant pumps, steam generators, pressurizar, polar crane, tanks, hept exchangers, etc.).
3.
pioing Systems and Supports Includes those safety-related piping systeIns described in 10. CFR 50.2(v) and R.G.1.26, quality gpoups A, B and C.
It is intended to be limited to the primary pressure boundary and other safety-related,'yater, steam and radioactive waste containment piping systems. It includes those quality checks necessary to ensure com-pliance'with the applicable codes and other requirements specified in the SAR fer these systems. The primary inspection emphasis in this area is on piping systems and their supports / restraints.
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- SYSTEMATIC ASSESSMENT OF 0516-04.01b4 LICENSEE PERFORMANCE 4.
Safety-Related Components - Mechanical Covers mechanical components such as pressure vessels.
pumps, and valves' located in, and attachedsto, the piping systems described in 3 above.
The primary emphasis here is on components rather than~ piping.
5.
Auxiliary Systems Includes those safety-related auxiliary systems included in the nu~ clear facility which 'are essential for th'e safe 4
shutdown of the plant or the protection of the health and safety of the public.
Included here are systems such as HVAC, radwaste, fire protection and fuel storage and handling.
6.
Electrical Ecuipment and Cables Includes safety-related 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.
switchgean., electric raceways, cable (power, cor. trol, and instrument), circuit breakers, relays and other interrupting and protective devices.
]
7.
Instrumentation
~
Covers safety-related instrument components and systems that are designed to measure, transmit, display, record
. and/or control various plant variables and conditions.
l The Reactor Protection System and the Engineered Safety Features Actuation System are two plant systems utilizing such devices as: sensors, transmitters, signal con-ditioners, controllers and other actuating devices, recorders, alarms, logic devices, instrument air supplies, racks and panels.
8.
Quality Programs and Admdistrative Controls Affectino j
oua nty r.
Includes all verification and oversight activities which affect or assure the quality of plant structures.
~
systems and components. This area may be viewed as a
- t-comprehensive management system for controhling the quality of work performed as well as the qVality of verification activities that confirm that fbe wqrk was performed correctly. The evaluation of thie effectiveness of the quality assurance system should be based on the results of management actions to ensure that necessary people, procedures, facilities and caterials are provided and used during the design and construction of the nuclear power plant.
principal emphasis should be e
Approved:
. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-042b8 given to evaluating the effectiveness and involvement of manag2 ment in establishing and assuring the effective implementation of the quality assurance prpgram along with evaluating the history of licensee / contractor performance in the key areas of: quality' assurance program,. design and procurement control, control of construction processes, inspections, audits, corrective action systems, and records.-
9.
Licensino Activities s
Includes all activit:ies seppdrting the'NRC review of the application for and the issuance o~f the Construc-tion Permit and Operating License, end amendmenti thereto.
In addition, it includes the adequacy and timeliness of all licensing submittals, responsiveness to NRC licensing' initiatives, and the applicant's or licensee's approach to resolution of technical issues i,
from a safety standpoint.
10.
Others (As needed) c.
Preoperational. Phase Reactors 1.
Preoperational Testine Covers the preparation, conduct and evaluation of test results for preoperational tests performed by or under o
the direction of theQ1censee's stafDto demonstrate 4-the proper functioning and conformance to design requirements of components, systems, and structures.
2.
.0thers (As Needed)
For reactors in the preoperational phase, functional areas from the listing for either operating phase reactors or construction. phase reactors should be
- elected as appropriate..e d.
Startup Phase Reactors
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1.
Startuo Testino s
Covers the preparation, conduct, and evaludion of test l
results for testing conducted following the:. issuance of l
the operating license. It starts with initial fuel loading and precritical tests, and continuel-hntil the plant reaches cocinercial operating status at or near its licensed power rating..
2.
Others (As Needed)
For reactors in the startup phase, functional areas O
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.=. $ SYSTEMATIC ASSESSMENT.0F 0516-042 LICENSEE PERFORFANCE from the histing for operating phase reactors should be used.
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~~
043 Performance Cateoories.
A rating of licensee performance in a given fu.ctional area.
7, a.
Cateoory 1 Reduced 'NRC attention may be appropriate. Licensee management attention ~ and. involvement are aggressive and oriented toward nuclear safety"; licensee resources are ample.and effectively used so that a high level of performance with respect to operational safety or construction is being achieved.
b.
Catecory 2 NRC attention should be maintained at normal levels.
Lican-see management attention.and involvement are evident and are concerned with nuclear safety; licensee resou'rces are ade-quate and reasonably effective so that satisfactory perform-ance with respect to operational safety cr construction is being achieved.
c.
Catecory 3 50th NRC and, licensee attentiori should be increased.
Lican-see management attention or in.volvement is acceptable and considers nuclear safety, but weaknesses are evident; licen-see resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to oper.ational safety or construction is being achieved.
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044 Trend. The general or prevailing tendency (tTe* perfoma.nce grad-1ent) cver the course of the SALP assessment period.
The deter-
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mination of the trend should not be forced.
In those instances where a prevailing trend ca'n not be determined, the SALP Board Report should state that the trend was not determined, and the reason for its omission should be provided (e.g., insufficient data).
a.
Imoroved Licensee performance has generally
- improved over the course of the SALP assessment period.
E b.
Same l
Licensee perfomance has recained essentially "cNstant over l l
the course of the SALP assessment period.
c.
Declined Licensee performance has generally declined over the course) annenumW
SYSTEMATIC ASSESSMENT OF LICENSEE PERFOR!WiCE 0516-044c of the SALP assessment period.
l
.045 Evaluation Criteria.
Elements which must be considered when assessing a. licensee's performance in a functional 4'rea.
a.
The evaluation criteria are as follows:
1.
Management involvement in assuring quality 2.
Approach to resolution of technic'al issues from safety standpoint s i
s 3.
Responsiveness to NRC initiatives 4.
Enforcement history',
5.
Reporting and analysis of reportable events 6.
Staffing (includingmanagement) 7.
Training effectiveness and qualification b.
Guidance for us4ng these criteria to arrive at a categ6ry assignment is found in the' Appendix to this Chapter.
4 0516-05 BASIC RIQUIREMENTS 051 Aeolicability. This Chapter applies to and shall be followed by hAC Heacquarters Offices and Regional Offices,
'052 Accendix 0516. Procedures for icplementationgf these diraqtives are presented in the Appendix to this Chapter.
END
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.O LICENSEE PERFORMANCE NRC APPENDIX 0516 s
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APPENDIX t
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-, SYSTEMATIC As5ESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 CONTENTS s
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Lut PART I GENERAL..............
1 l
PART II EVALUATION CRITERIA.'........'......
3 PART III SALP BOARD ASSESSMENT..i.. r.........
11 i
PART IV MEETING WITH LICENSEE..........*.....
17*
ISSUANCE 0F REPORT.'..............
19 PART Y PART VI APPENDIX TO THE SALP REPORT........... 21 i
l PART VII FORMAT FOR SALP REPORT 23 l
i FIGURES FIGURE 1 SALP EVALUATION PROCES$....,.........
2 TABLES
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TABLE 1 Evaluation Criteria With Attributes for Assessment of Licensee Performance
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TABLE 2
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Evaluation Matrix for Operating Phase l
Reactor Functional Areas 13
- t TABLE 3 Evaluation Matrix for Construction
, Phase Reactor Functional Arpas 15 i
l EXH!llTS 1
IIHIBIT 1 -
Examples of Overall Safet
,. Characterizations....y Performance
.,.. g. 24 I
- EXHIBIT.2 -
SALP Boa rd Report............. '. '-I.'
2'5 i
EXW18173-An Errata Sheet...............
35 l
EXHIBIT 4 -
Original Page................
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EXHIBIT 5 -
, Corrected Page 37 j
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e SYSTEMATIC ASSESSMENT 0F
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NRC APPENDIX 0516 LICENSEE PERFORMANCE PART I PART I
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GENERAL
.A.
The SALP program was established to improve the NRC Regulatory Program, to permit sound decisions regarding NRC resource allocations, and to better understand the reasons for the performance of each reactor licensee.
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B.
The NRC will conduct a review and evaluation of each power reactor licensee possessing an operating license or construction permit every 18 months except:
1.
When the Regional Administrator determines that a particular utility or facility should be evaluated more frequently; or 2.
When a SALP Report will be used as part of an evaluation of readiness for license issuance (IE 94300), a SALP evaluation should be scheduled approximately six to nine months before the scheduled licensing.date.
The individual facility ass'essments are intended to take place at an approximately uniform rate throughout the year within each Regional office.
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C.
The evaluation process is composed of (Figure 1, Part I):
1.
A SALP Ecard assessment; 2.
Issuarce of the SALP report;
- 3. - If requested by the licensee or if otherwise determined to be necessary by the Regional Administrator, a meeting with licensee managementtodiscusstheassessmen,1,;and 4.
Consideration of any written commerits received from tre licensee and issuance of an appendix tot)re SALP report which is to include the verbatim written cor.ents received from the licensee and the conclusions of the Regional Administrator on the basis of
~
his consideration of the comments.
Procedures for implementing the SALP program are provided.in this Appendix.
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's SYSTEMATIC ASSESSMENT OF NRC APPEliDIX 0516 LICENSEE PERFORMANCE
.PART II.
FIGURE 1 SALP Evaluation Process.
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SALP Board Preparation (PartIII)
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SALP Boa'rd Meeting (PartIII)
SALP' Report Issuance (PartV) 1 Meeting with the Yes Licensee 7 O
G 7fieting.'with the Licensee (PartIV) g
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Licensee Responds O
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r-Appendix to f,~.
the SALP l
Report (Part VI) a 2-i
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. SYSTEMATIC ASSESSMENT OF
...,_,,,.-C NRC APPENDIX 0516 LICENSEE PERFORMANCE PART II e
PART II EVALUATION CRITERIA The assessment 'of licensee performance is implemented through the use of seven evaluation criterfa. The criteria provide standard guidance that shall be applied to each func.tional area for the categorization of licensee perfomance.
~
To provide consistent evaluation of licensee perfomance, several attri-betes associated with each criterion are listed to describe the character istics applicable to the three categories.
The seven criteria discussed iri Chapter NRC-0516-045 are listed in Table 1 with their associrted attributes. These. form the guidance which aids in understanding and evaluating licensee performance by identifying the causes and factors appropriate for categorization.
It is not intended that con-si:'eration of these attributes influence established programs of the agency. For example, it is not intended that. specific inspections be performed to evaluate attributes.
It is expected that during the implemen-tation of established programs, many of the attributes which describe performance will be observed.
Cognizance of these attributes should assist the staff in their observation of licensee performance during routine activities.
All of the attributes of the evaluation criteria are not necessarily applicable.
In some instances, the observed performance within a func-ticnal area may be. insufficient to allow consideration in the evaluation.
Co.versely, additional attributes may be appropriate fo' r the evaluation.
Matters such as management involvement and training a'reTriteria cf' ea'ch functional area and should be considered in the evaluation of the func-tional areas, On the other hand, if there is a problem with one of these criterion that is observed in several' functional areas. it may be desirable to highlight that criterion in a separate discussion; e.g., training may be a problera in Plant Operations, Radiological Centrol and Surveillance.
It weald be appropriate to discuss trainingJs.if it were a functional area, in addition to ' covering the specific trainfag problem in each functional area.
It. is emphasized that all available information should be analyhed by the SALP Board, and its significance, whether it be positive or negative, should be weighed.
If information is scarce or nonexistent, a-tfecision regarding the performance category or trend as it relates to arf-attribute sh:uld not be forced.
u.
(
m
- - - - - - - ' ' - ' - ~'
v W.
I l
ay TABLE 1 EVALUATION CRITERIA WITil ATTRIBUTES FOR A55E55HENT OF LICENSEE PERFORMANCE 5:e m.9.
g
,, n g
Category 1 y
- Category 2 Category 3 Evi GU '
^
.. m v.
-R..
~.
a k.
Management inv. lve, ment and Control in Assuring Quality n'
i o
.g consistent evidence of prior evidence of prior planning and little evidence of prior
~~
planning and assignment of assignment of priorities; planning and assignment of l.-
priorities; well stated,
' stated defined procedures for prioritles* poorly stated or
.~
rll '.
centrolled and. explicit control of activities.
,ill'unders[oodproceduresfor
~ control.of activities procedures for control of.
i
. h..y'd ' "i
-Q:
- activities i
?-
d.[,b.r%d.Q.;l'l:'..ii wellsi.ated, disseminated..and adequately stated and
'poorly stated, poorly
?? ' : Pofici.es....or nonexistent g,ig:)
understandable policies understood policies understood 2
.t
.s i
decisionmaking consistently A
decisionmaking usually at a decisioimaikfing seldom at a a level that ensures adequate level that ensures adequate Icvel that ensures adequate canagement review '
. management review managemenfreview corporate management frequentl
'corpkrate'managementusually corporate management seldom
.. involved in site activities' y Involved in~ site activities involved.in site activities M
=
[;.u. t..t audits complete, timely, and,
audits Dener' ally complete,
'auditsfrequentlynob,,'LImely,
.g
. thorough timely, and thorough incomplete,,or not thorough 2,
gx
.i
.g
- -. g.
j
[
i
iw
~'
s,
. h, ",
Category 1 Category 2~
.ga Category 3
-e f.
-m 1.
[lanagement In'volvement and control in Assurina Quality (Continued)
M
- a..
.-m v.
~
2-4
. committees properly staffed and, committees usually properly
- 6a functioning in almos.C a'll cases itaffed and functioning or functioning, prop.drly staffed
' committees not reviews timely, thorough,'and reviews generally timely,-
" reviews not timely thorough,
,g. k.-
technically sound
, thorough, and technically. sound 1
,or technically soun,d f'
j
~
records complet'e, well.
wellmaintained.,hcomplete
' records not complete not well records genera 11 and a5allable'$Y',,'P)maintainede'or unavallable i.ij 1!.i caintained, and available I
- ij.y.i.
t i'
%..,..:,;. :.. lls. ;..
/.
I precedures and policies procedures and policies rarely
. procedures and policies
'p..,
strictly adhered to violated
, occasionally violated
,g jj:.,,
correct.ive action sys'tems'\\
correc'tive action systems corrective action systems i
E
~
promptly and consistently generally recognize and address rarely recognize and address
,I recognite and address nonreportable concerns nonreportable concerns.
i nonreportable concerits 4
precurement well controlled and jrochrementgenerallywell
' repet'itive breakdown in M
documented controlled and documented procurement control M
4 cm i
j '
s...\\.:
design well co;ntrolled and yf
.:. ; s rare breakdowns of minor 5in';
repetitive breakdown in design verified significance in design control control or. verification i
4 AM mm
,, m QR pg-2 I-Q Q Q-
- ;,qn Category 1 Categor[2 Category 3
' QM g Q, "
- ?h l
2.
Approach th Res,olution ef' Technical Issues from a Safety Standpoint -
- gM Eil
clear understanding of isiu'es understanding of issues understandin~ of. issues kN demonstrated-
. generally apparent frequently 1 cking I,
5 g
meets minimum requirements 5,.lil censervatism rohtinely *.
conservatism generally',* "
~
exhibited when potential for exhibited safety significance exists j
s
. technically sound and thorough viable and generally sound and '.:' ofLeit viable approaches; but
. i.
approaches in almost all cases thorough approaches lacking in thoroughness or d'epth I.
\\
timely resolutions in almost generally timely resolutions res,olutions..of' ten delayed a11 cases
.y j
..y s
1
,g
- c is.'.
, e
~
3.
Responsiveness to NRC Initiatives 4
I meets deadlines generpily, timely responses fregijently regtilres extensions
)
of time l
i timelyresn'1'6kiSHofissues few longstanding regulatory longstanding regulatory tissues-k l=.,
issues attributable to licensee attributable to licensee g
L E
i s
5"U d:a
~
I j'
4
CateDory 1 Category 2 Category 3_
3; d....
y 1'
,,r 3.
Responsiveness.to NR0 Initiatives (Continued) m
.G.
technicallysoundandtheion[th"v'iablea'ndgenerallysounda.nd oftenvinh1[ responses,but h.
. responses in almost all, cases thorough responses lackinginthoroughijessor g;
i 5*
depth acceptable resolutions proposed acceptable resolstions.
considerable NRC e urt or initially in most cases
' generally proposed.... :
repeated submittals needed to
... P
.f>l
- ' 6bta.in. acceptable resolutions
.T,
- s
- l 4.
Enforcementllistory y
cajorviolat.ionsarerareand major violations are rare and inultjple sgjor violations'or
~
cre 'not indicative of may indicate minor programmatic programmatic breakdown
~..
,6
' x,-
breakdown indicated pregrammatic breakdown is 4
~
j cainor violations are not multiple minoi violations or,
minor violations are repetitive repetitive and not indicative minor programmatic breakdown and indicative of programmatic i'
I of programmatic breakdown indicated breakdown E
i t'.
t corrective acti'on is pron.pt and corrective action is timely and corrective-action is delayed or E
I effective 'Ti r,'.s:
not ef fect,ive r-M
-i effective in most cases
,. ; t, M$
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e,,y J
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0
~}vs.
C,.atcg,ory_,1
, Category 2 Category 3
~
fjl g
., y
~ !i.
Reporting.in'dAnalysis.of'.'ReportableEvents' "d
y, n i
s...
MR events are promptly and I_.,,
events are reported in a timely event reporting'.is frequently y.I completely reportef,',
.. manner, some,information may be late or incomplete ;'
gv.
l 1acking dili '
mg g
.eventsareproperTyidentified events are accurately events are poorly identified or and analyzed identified, some analyses are analyses are marginal. events l
inarginal
're associated with i
a
. programmatic seaknesses corrective action is effective, correctiveactionisuskally.
torrective at: tion is not tim'ly.
g'<;
i e
D as indicated by lack of taken but may not be effective, nor effective, events are ep;'r i
repetition as indicated by occasional
. repetitive repetition
'. :. 5),'.
3 Staf fing (Including' M$ nan.epent).
G.
.f positions are identified, key positions are idintified, positions are poorly l
s authorities and
. and authorities and identified or authorities and i
responsibilities are well J:espgnsibilities are defined responsibllltiesareill-defined
)
defined N
.,;.f.c:,
g.
a n
,..m n;
m
,.5
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Sg j
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s Catcgory,1 Category 2-0 Category 3 d'.
H
.4 Staffing ( nc1N,.-
i 3..
, G.
ding.Hanagement) o x.
vacantkeyp'ositionsareillled"*.keyposill'ensusually. filled.In
~. key posillo'ns are left vacant g
.cn priority basis,,,
,_,a reasonable time
'for. extended periodd of time g*
'~
staffing is ample as indicated
-staffing is adeguate staffirg is wdak or minimal as by control over backlog and occasionaldifficultleswith..
indicated by excessive backlog-t overtime backlog or overtino...
-l and overtime.
.'.r.
{-
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' 7.,
Training and Qualification Effectiveness
" '.' i.
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,.c
.s.
training and qual.ification
. training and qualification
.. training and qualification program makes a positive program contributes to an
' program is found to be the contribution, commensurate with adequate understanding of..
malor contributing factor to
..i.'
i s
procedures and starring, tq work and fair adherence to poor understanding.of work, dure as..
. understanding of work and procedure with.a modest number indicated by numerous proce j
adherence to. procedures with *"-
of personnel errors violations or personnel errors few personnel errors
\\
r training program'is well a dePined program is
. program may be either lacking,
,M defined and implemented with impliknentdd for a large portion poorly defined, or
- g5 dedicated resources and a means of the staff ineffectively applied for a si nifican.L' segment of the
$n;-!
m for feedhagi; cycrience i
programistappithdtone;arly D
staff
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@ rTi 24 RM i
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. SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART III
^
PART III SALP BOARD ASSESSMENT
<A.
SALP Board Preparation 1.
Each Region shall issue a memorandum establishing the assessment period, SALP Board ' input due.date, SALP, Board meeting date, and date of licensee meetino, if necessary, for all facilities within the RegionCfor all SALP meetinos to occur in the ca sencer veer. ]
This memorandum shall be sent to fiRR, IE, fr.SS, AE00, and the. EDQ j
oy the end of tne preceding ca.lencar year.
SALPBoardmemoerg ill be notified promptly of any unavoidable changes.
2.
Prepare the SALP Board Report.in a preliminary form.
~
a.
Obtain SALP Board inputs. NRR, IE, AEOD, and NMSS shall provide a written input.
If the Office does not have sufficient basis for an input, the Office shall state.
that fact to the Region by memorandum.
b.
Prepare the Supporting Data Sunrnary section of the report.
(See Part VU, Exhibit 2 for fdrmat.)_
c.
Prepare a performance analysis' for each of the functional areas identified in NRC 0516-042.
(See Part VII Exhibit 2 for fonnat.)
4 B.,. SALP Board Meeting
- 1.. The SALP Board meeting should be conducted within 45 days after the end of the assessment period.
2.
The SALP Board shall be composed of p
a.
.SALP Board Chairman (Branr.h., Chief or above) b.
NRR Project Manager
~
c.
NRRmanagementrepresentative(participationissfurther described in NRR Office Letter 44) d.
' Senior Resident Inspector I
.~-
e.
Representatives from IE, AEOD, and H".SS as appfopriate f.
Other individuals as determined by the Regional Administrator i
RS1
jNRC APPENDIX 0516 -
" SYSTEMATIC ASSESSMENT OF PART III LICENSEE PERFORMANCE 3.
During the SALP Board meeting, the SALP Board shall:
a.
Review and discuss the draft SALP Board Assessment report.
Ensure that sufficient information has been provided in each' functional area analysis to form a conclusfon recarding licensee performancefor alternatively confirm inat suffi-]
d
~~
Eient information is not available to support a conclusionj e.
ardino licensee performw=
i b.
Rate licer.:ce perfor.ance in each functional area after
.considering the evaluati.on criteria with their associated.
attributes listed in Table 1 of Pa'rt II o,f this appendix.
j Tables 2 and 3 may be used by the SALP Board members to assist them in their rating of a licensee.
- c.
Recomend revisions to th inspection program, as necessary.
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. SYSTEMATIC ASSE55HENT OF
/ ~"
NRC APPENDIX 05I6 s
LICENSEE PERFORMANCE PART'IV PART IV l
J-MEETING WITH LICENSEE
,'A.
General.
If requested by the licensee or if otherwise d5termined to te necessary by the Regional Administrator, a meeting with licensee canagement to discuss the assessment will be held.
e.
B.
Meeting Preparation' I.
Notification of the meeting (1f hel5) s'hould be niadehy the rem atleast(onemonth]inadvance. Notification should be made to the licensee, Ine resident inspectors at the involved facilities, the NRR Project Managers for the involved facilities, and cognizant '
i NRC managers..
2.
The licensee should be encouraged to have the following manage-ment representatives participate in the meeting.
1 l
a.
Senior corporate management representative b.
Management officials responsible for the major functions wherein problem areas have been identified (e.g., health physics, security, engineering) c.
Site Manager i
~
C.
Meetine with Licensee l
1.
The meeting (if held) should be conducted vithinhdays after
[
the end cf the assessment period.
- 2.. NRC representatives for this meeting should include the following:
a.
Either the Regional Adninistrator, Deputy Administrator, or Division Director
-i l.
?
b.
, Responsible Regional Divis.fon Director (s), Branch Chiefs, l
or Section Chiefs, as appro'priate NRR Project Managerhdesignated,NRR aanager Y
- c..
d.
Resident Inspector and/or assigned inspectors 6
Public Affairs Officer, when media interest fs[ anticipated 3.
The Regional Administrator, Deputy Administrator, EDiv'ision Director will chair th' meeting and discussions of the adequacy e
of the licensee's canagement controls. These meetings are ir. ten.ded to provide a forum for candid discussion of issues relating to the licen'see's perfomance. Those aspectr of the licensee's operation that need improvement will be identified.
t 17 -
)
NRC APPENDIX 0516 -
-SYSTEMATIC ASSESSMENT OF PAP.T IV LICEllSEE PERFORMANCE The licensee will also be given the opportunity to make com:ents on the report in writing withir 30 days after the meetinpor
-1.
receiot of the SALP Board report if no meeting is held.
ny written coments from the licensee must ce addresset.by the Regional Adininistrators.
9; 4.
SALP management meetings with the licensee should be conducted as open meetings, with the exception of those portions of the teetings
'that involve ' discussion of matters not required to be mandatorily placed in the publi.c domain pursuant to 10 CFR 2.790 which must be closed. Members of the pubite should be treated.as observers..
Adequate notification of the SALP meeting can be' accomplished by PDR distribution of the letter to the licensee which schedules the meeting, with copies to the service list for.the appropriat'e docket.
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. SYSTEMATIC ASSESSMENT OF
~
NRC APPENDIX 0516 c
LICENSEE PERFORMANCE PART V PART Y
~
ISSUANCE OF REPORT
- [
A.
Issuance of Report The SALP Board Report (Exhibit 2, Part VII) shal'1 be transmitted by the Regional Administratbr to the. licensee with copies,to NRR and IE.
The transmittal letter should include:
1.
A request for licensee's written coments and amplification, as -
appropriate, on these coments, within 30 days'after the meetin'g (ifheld)orreceipt,oftheSALPBoardreport; 2.
Amplification of the findings of the SALP Board as appropriate.
This includes, as a minimum, functional areas rated Category One, Category Three and those functional areas which have declined since the last SALP evaluation period (examples are shown in Exhibit 1. Part VII); and 3.
A characteri.zation of overall safety performance.
This letter, enclosing the SALP Report, will receive standard docket distribution including the NRc public Document Room and the local
'p Public Document RoomJand INPO (Record Center. INPO: 1100 circTe 75)
Garkway: Suite 1500; Atlanta, GA 30339)pach report will be assigned an Inspection Report numer.
S.
. Chancing the SALP Report x
Any, changes made to the report as originally transmitted to the licen-see shall be done using the following procedure (an example is shown in Exhibits 3, 4, and 5, Part VII).
Include an errata sheet (Exhibit 3)Part VII) as a separate en-a.
closure to a Regional Administugor's cover letter denoting the change and the basis for the change.
b.
Add the corrected page (Exhibit 5, Part VII). to the report, leaving the original page (Exhibit 4 Part VII) in tHe report.
c.
Makeadiagonallinethroughtheoriginalpage,ref%ncingthe Errata sheet.
ud g.
l
~
g
i SYSTEMATIC ASSESSMENT OF-
'. '~
=.:..0 NRC APPENDIX 0516 LICENSEE PERFORMANCE PA9T VI PART VI
" ~
APPENDIX TO THE SALP REPORT f
A.
General After receiving ths licensee's written con ents, the Regional Administrator shall-issue an appendix to the SALP report within 30 days. This appendix will receive standard docket distribution including the NRC Public Document Room, the local Public Document Room and INPO.
B.
Appendix to the SALP Report The a'ppendix to the SALP report shall consist of:
1.
The verbatim written conrnents received from the li'censee; 2.
A summary of any meetings held with the licensee concerning the
~
SALP report; and.
3.
The cone.lusions of theCRecional Administrator)on the basis of
/-
his consideration of the licensee's comments.
men e
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. SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERPORMANCE PART VII PART VII i
{
SALP REPORT I'.
FORMAT AND CONTENT A.
General s
The SALP Board report is considered tc be a final report upon approval by the Board and dispatch to the 1,1censee.
B.
Multiple Facility Licensees In cases such as Duke and Connonwealth Edison, the SALP package may address more than one site. However, each site must have a separate.
SALP Board Report (Exhibit 2, Part VII).
C.
Report Torr.zt and Content The SALP Board report shall be prepared in general conformance to the guidelines provided in Exhibit 2.
The standard entries described in this Exhibit should be used to the extent possible.
e
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-. ~.
.-;;. SYSTEMATIC ASSESSMENT.0F 4 NRC APPENDIX OSI6 PART VII LICEf!SEE PERFORfMNCE EXHIBIT 1 Samples.of Overall Safety Perfomance Chacterizatiops n
Example 1 Overall, we find that your performance of licensed activities generally is acceptable and directed towar' safe facility operation.
In addition,'your d
overall performance has showed only moderate improvement since the last SALP evaluation period. Your performance in the area of Plant Modifications with contractors having limited experience was found to,be in need of increased management attention.
Example 2 In addition to the assessments and recommendations made by the SALP Board' in the enclosed SALP Report, it is my view that your overall regulatory performance continued at a high level during the assessment period. It is 4
evident that safe operation and compliance with regulatory requirements er priority considerations at your facility.
I concur, however, with the SALP Board findings that management attention is required to correct problems in the area of Radiological Cqntrols and the long standjng problems associated with the existing perimeter alann system.
Example 3 The overall performance of your facility was acceptable (,pt exhibited a declining trend since the last SALP evaluation period.
Resources were strained. or not effectively used such that minically satisfactory perform-ance with respect to operational safety was achieved. The SALP Board identified weaknesses in the areas of plant operations, radiological controls, mintenance, security and safeguards, and the quality assurar.ce program. Your performance in these areas wilt be closely monitored and
. discussed in the next SALP Board Assessment <for your facility.
A major
\\ strenfh was noted in'the area of refueling'-
Examole 4 s
Okerall, we found your perforinance acceptable and directed toward safe.
facility operation.
In addition, we found your overall perf6i]6ance im-l proved since the last SALP avaluation period. We found agres.s4ve manage-ment attention and a high level of perfonnance in the following areas:
Radiological Con'.rols Surve111ance, Fire Protection and Housekeeping, Emergency Preparedness, and Refueling. Your performance in assuring that I
equipment and procedural changes and adequately controlled was found to need increased attention.on you' part and we will pay particular attention c
i to this area during our subsequent inspections.
24
i NRC APPENDIX 0516 -
SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE '
EXHIBIT 2
~
SALP BOARD REPORT 4
U.S.- NUCLEAR REGULATORY COMMISSIO'N REGION [ region]*
SYSTEMATIC ASSESSMENT'0F LICENSEE PERFORMANCE
[ Inspection Report Number]
[Name of Licensee]
[NemeofFacility)
~
~
[ Assessment Period]
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NRC APPENDIX 0516 1-
. =. ncSYSTEMATIC ASSESSMENT.0F f
PART VII LICENSEE PERFORMANCE EXHIBIT 2(Cont'd)
~
I.
INTRODUCTION
,r The Systematic Assessment of Licensee Performance (SALP)7 program is
~~
an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based e.
upon this information.
SALP is supplemental to normal regulatory processes used to ensuret compliance to NRC rules and regulations.
SALP is intended to be s,fficiently diagnostic to provide a rational u
basis for allocating NRC resources and to provide mean'ingful guidance to the licensee's management to promote quality and safety of plant construction and operation.
A NRC SALP Board, composed of the staff members listed below, met on
[date),toreviewtheco1Tectionofperformanceobservationsanddata to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516. " Systematic Assessment of Lice ~nsee Performance."
A sumary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Beard's assessment of the licensee's safety, performance at [name of facility] for the period [date] through [date].
SALP Board for [name o_f facility]:
[ List SALP Board Members]
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< SYSTEMATIC ASSESSMENT 0F NRC APPENDIX 0156 LICENSEE PERFORMANCE PART VII EXHIBIT 2(Cont'd) s
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11.
CRITERIA Licensee performance is assessed in selected functional areas, depending whether the facility is in a construction, preoperational, or operating phase.
Each functional area normally represents areas significant to nuclear safety and the environment, and are norm,al programmatic areas.
Some functional areas may not 'be assessed because of little or no :
licensee activities or lack of meaningfut observations. Special areas may be added to highlight significant observations.
One or more of the following evahation criteria were used to assess each functional area.
1.
Management involvement and control in assuring quality 2.
Approach to resolution of technical issues from a safety standp'oint 3.
Responsiveness to NRC initiatives
~
4.
Enforcement history 5.
Reporting and analysis of reportablai events 6.
Staffing (includingmanagement) 7.
Training effectiveness and qualification However, the SALP Board is not limited to,these cr3eria and othys may have been used where appropriate.
Based Iipon the SALP Board assessment each functional area evaluated is.
classified into one of three performance categories. The dafinition of these performance cat 2gories is:
-i
?
- Cateoory 1.
Reduced URC attention.Jnt,y be appropriate. Licensee management attention and involvement 4re aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so
)
that a high level of performance with respect to operational safety or 1
.;.. construction is being achieved.
1 Cateoory 2.-
NRC attention should be maintained at normaf levels.
Licensee management attention and involvement are evident and are concerned with nuclear. safety; licensee resources are a#tiuate and are
, reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieved.
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4 NRC APPENDIX 0516
".:.- ::..c.0 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE EXHIBIT 2(Cont'd)
Cateoory 3.
Both NRC and licensee attention should be fiicreased, i
Licensee management attention or involvement is acceptabli and con-siders nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satis-factory performanci with respect to operational safety or construction is being achieved. -
III.
SUMMARY
OF RESULTS
\\
[ Provide a narrative summary of. tlfe. licensee's overall significant strengths and weaknesses.
It should be similar to the overall
)
performance narrative used in the letter to the licensee.]
Functional Area
[last periodl
[this period]
Tr'end
[functionalarea)
[ratinglast
[ rating)this
[ trend]-
-period]
period
..e 1Y.. PERFORMANCE ANALYSIS A.
[FunctionalAreabeing' discussed) 1.
Analysis e
[The analysis of theNeensee's performance in an area should include pertinent facts and observations to highlight the specific strong and weak aspects of the licensee's performance.
These facts and observations shall be pres'ented in a manner to place matters in perspective and to allow the reader to understand the rationale for stated conclifs: ions'. This analy-sis should concentrate on the adequacy of the licensee's management control systems, adequacy of ri[ourc'es, training of personnel, etc., and the effectiveness of these efforts.
Upon presentation of the analyses, the attributes associated with the specified criteria are to be referred to for purposes of both completeness and to compare the conclusions reached j
with.the attributes of each category. The attributes listed in Part II are specifically oriented toward this z
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' NRC APPENDIX 0516
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.0 SYSTEMATIC ASSESSMENT OF c
PART VII LICENSEE PERFORMANCE EXHIBIT 2(Cont'd)
Cateoory 3.
'BothNRCandlicenseeattentionshouldbeijereased.
Licensee management attention or involvement is acceptable and con-siders nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satis-u factory performanci with respect to operational safety or ccnstruction is being achieved. -
III.
SUMMARY
OF RESULTS
[ Provide a narrative sumary of. tife. licensee's overall significant
~
strengths and weaknesses.
It should be similar to the overall performance narrative used in the letter to the licensee.]
Functional Area
[last period]
[this period 3 Tr'end
[ functional area)
[ratinglast -
[ rating)this
[ trend]-
--period) period l
IV.. PERFORMANCE ANALYSIS A.
[Functinnal Area being discussed]
1.
Analysis
.e
~
[The aralysis of the 18censee's performance in an area snould include partinent facts and ebservations to highlight the specific strong and weak aspects of the licensee's performance.
These facts and observations shall be presented in a manner to place matters in perspective and to allow the reader to 7
understand the rationale for stated conclus: ions. This analy-i sisshouldconcentrateontheadequacyof3helicensee's management control systems, adequacy of resources, training of personnel, etc., and the effectiveness of these efforts.
Upon presentation of the analyses, the attributes assoc.1ated with the specified criteria are to he referred to for purposes of both completeness and to compare the conclusions reached l
with.the at-tributes of each category. The attributes listed in Part II are specifically oriented toward this i
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's SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516-PART VII LICENSEE PERFORMANCE EXHIBIT 2 (Cont'd)
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and-should be utilized.
In no event, however.are the examples of licensee performance for specific attributeF to be used as stand-alone assessments; they represent a sampilng of possible conclusions which must be support to by appropriate facts, observations or analysis.
Each (Salysis should be written to avoid either 10.,CFR 2.790 or safeguards information.
The analysis section is composed df three mijor subsections:
A brief account of the inspection activity which' occurred in this area.'
~.
A brief surirnary of the previous year's evaluation if there has been a significant change or if there should have been significant improvement but there was not.,,
A sumary of the strengths, weaknesses, and other significant observations made by the NRC staff during the evaluation period.]
~
2.
Conclusion
[ Provide the performance assessment and trend (Improved, Same, Declined)(for each functionalCategory i
area considered and if appropriate, a surmary assessment.]
3.
Board Recommendations
[ Recommend NRC actions to be taken, if"a'ify are 'requ'ireti. A j
basis for changes in the NRC program must be provided. Note that even in the absence of a reco.mendation to vary inspec-tion levels, the Regional Office may do so based on the i
assessment as discussed in appropriate chapters cf the IE manual.]
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.#RC APPENDIX 0516
' - __, 5. SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE EXHIB'IT 2 (Cont'd)
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if.
SUPPORTING DATA AND SIM MRIES
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A.
Licensee Activities e
[ Provide an outline of major _ licensee activities, such as major p
outages, power limitations,Gmportant ncensee amendmenui and j
significant modifications.]
B.
Inspecticn Activities
[ Provide a sununary of major inspection activities, such as major team inspections.
Include Table 1]
C.
Investigations and Allegations Review
[ Provide a sununary of major investigative activities and their results.]
D.
Escalated Enforcement Actions a.
Civil Penalties [ Provide a sunnary]
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b.
Orders (only those relating to enforcement) [ Provide a suecary]
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E.
!!anagement Conferences Held During Aooraisal' Period,
',a.
Conferences [ Discuss conferences that dealt with regulatory i
performanceorenforcement.]
- b. hnfirnatica of Action Letters [Provice a siennaryh y
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[ Discuss any other issues at the discretion of the SALP Board.]
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. F.
Review of Licensee Event Reoorts, Construction Deficiehey Reports, and 10 CFR 21 Reports 7-
[ Provide a brief sunnary of significant findings trends]
8 resulting from a review of these reports.]
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SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICEf:SEE PERFORMANCE PART VII EXHIBIT 2 (Cont'd)
TABLE 1 INSPECTION ACTIVITY AND ENFORCEMENT FUNCTIONAL INSP.
NO. OF VIOL TIONS IN EACH SEVERITY LEVEL AREA HRS.
V IV III II
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HRC APPENDIX 0516 l-
' SYSTEMATIC ASSESSMENT OF l
PART VII LICENSEE PERFORMANCE EXHIBIT 2 (Cont'd) 1 TABLE 2 i
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LICENSEE EVENT REPORTS-z.
e NUMBER DESCRIPTION
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.NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERF0Py.AfiCE EXHIBIT 2 (Cont'd)
TABLE 4
[r 10 CFR PART 21 REPORTS-c NUMBER DESCRIPTION g
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,s AN ERRATA SHEET l'.
SALP BOARD REPORT ERRATA SMEET PAGE LINE h0W READS
'SHOOLD READ.
5 24 operator'scoanitNedecision operator's decision Basis: The word cognitive was deleted to avoid further problems in interpre-ting its meaning. As used the work was intended.to niean 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 a manner which he felt was eqyiv-alent to the requirements. It was not intended to mean that the operator took actions in total disregard of the Technical Specification
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- /+*NRC APPENDIX 0516 SYSTEPATIC ASSESSMENT OF PART VII
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LICENSEE PERFORFANCE s
S EXHIBIT 4 ORIGINhl PAGE (10)
Severity Level IV - Failure to tike timely and propet corrective e
' action following the failure of a cold leg.RTD (50-000/81-24).
(
- Failure to make's 30 day report on a *de' graded bus voltage' relay (50-000/81-26).
Six of 'he noncompliances were for ' failure to make, required reports or to make imely reports, four for fM1ure to follow procedures, and bne' for incomp'ete documentation.
One noncompliance for failure to proptrly report'a br ch in' containment Item (g) above, is part of an escalated enforcement a ion with Civil Penalty. The actual event, is described in Section 4 rveillance.
Nine LER's relatin to this area were' caused by personnel errors, six 1
at Unit I and three t Unit 2.
Sixty percent of these occurred in the last half of the peri arrd thirty percent in the last quarter indicat-l ing an increasing occur nee rate in the period.
Six of the nine were for incorrect valve or b ker alignments.and three were for failure to follow operating procedure Twoevents(LER's 50-000/81-6e %d50-000/81-52) were of particular concer'n since they reflected a
- =nsed operator's cognitive decision to cperate a system (charging and le a'nd containdent isolation, respectively) in a manner not allow b the Technical Specifications.
R w
Unit 1 experienced nine automatic t ' Ey ing the evaluation period, four caused by operator error and five equipmer(t, failure. Of the four caused by errors, two were due to rrect)y conducted instrumen surveillance tests, one to an incorrect y lineup on the steam side, l
'and the last to unfamiliarity with turbip,e
+rols.
Unit 2 experienced nine reactor trips /Ine bei.
manually initiated turbine trip.
Four of the trips were related to l errors; two by loss of vacuum in the ' main condenser, one resu); sonne from a low steam
~
- L generator, level, and one resulted from a turbine va
_ misalignment..
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5'No significant safety coni:ern is associated with these tr_. s and each was reviewed to verify proper safety system operation and-erator actions.
.v Various operating problems and events identified during the per1 d resulted in an enforcement meeting on August 4,1951, with follow meeting on August 4,1951,,with followup meetings on Nove.ber 2,15
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SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516-s
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- ! E CENSEE PERFORMANCE ~
PART VII l
EXHIBIT 5 CORRECTED PAGE (10)
Severity Level IV - Failure to take timely and proper corrective action following the failure of a cold leg RTb (50-000/81-24).
(11)
Severity Level VI Failure to make il 30 day report on a-degraded bus voltage ' relay (50-000/8126).
Six of the noncompliances.were for ' failure to make required reports or to make timely reports, four for failure to follow procedures, and one for incomplete documentation.
One ' noncompliance fo'r failure to properly report a breach in containment Item (9) above, is part of an escalated enforcement action with Civil Penalty. The actual event, is described in Section 4. Surveillance.
Nine LER's relating to this area werdt caused by personnel errors, six at Unit I and three at Unit 2.
Sixty percent of these occurred in the last half of the period and thinty percent in the last quarter indicating an increasing occurrence rate in the period.
Six of the nine were for incorrect valve or. breaker alignments and three were for failure to follow operating proced.ures.
~
Two events (LER's 50-000/81-67and50-000/81-52) were of particular concern since they reflected a licensed operator's decision to operate a
~
system (charging and letdown and containment isolation, respectively) in a manner not allowed by the Technical Specifications.
IJnit:1 experienced nine automatic trips during th5aluation'perlod, four. caused by operator error and five by equipment. failure. Of the f6ur cau' sed by errors, two war.e due to incorrectly conducted instrument -
surveillance tests, one to an ine'orrect valve lineup on the steam side, and the last to unfamiliarity with turbing controls.
Unit 2 experienced aine reactor t'ript,;4ne being. a manually initiated turbine trip.
Four. of the trips were r' elated to personnel errors;.two by loss of vuuum in the. main condenser,, ane resulted from a low steam
- ~
generator level, and one resulted from a turbine valve misalignment.
4 No significant s'afety concern is associated with these trips and each
' was reviewed to verify ' proper safety system operation and, operator actions.
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Various operating problems,and events identified during.t_h.e period I
resulted in an enforcement meeting on August 4,1981, with follcwup meeting on' August 4,1981, with fol,lowup meetings on November 2,1981 5
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