ML20132C524
| ML20132C524 | |
| Person / Time | |
|---|---|
| Issue date: | 11/15/1984 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20132C529 | List: |
| References | |
| FOIA-85-336 NUDOCS 8411260438 | |
| Download: ML20132C524 (49) | |
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Richarc C. DeYoung Director Office cf Inspectioi id Enforcement 5;5/ECT:
REVISED SA;.P MAhtiAL CHAPTER (NRC 0516)
M 4 'cr 12, 1964 y
memorancar forwarded a copy of the revised Syster.atic Assessre:
c' ticenset Ferformance (SALP) NRC Manual Chapter (NRC 051f).
inat rentrance rewestec that the revised M; be put in effect as soon as possible bs*. shoulc not tr,terrupt.50s then in progress. The formal issuance of the M: mas postponec pending resolution of several issues.
These issues were ctscussec curieg the NRC management meeting held October 10 and 11.1984 At thtt meeting the participants agreed that because the current draf t of the SALF Nrsal Chapter reflects current policy and practice, the current version be iss.,ec as intertr guidance.
The enclosed version of M NRC 0516 is forwarced f cr ycv implementation.
This version is similar te the one forwardeo to you c, r Nrch 12, 1964 semoranoum, with the exception of changes te the sup-Dcrting Cata and summaries section that reduce and clarify the informattor.
recatred to be providec.
By copy of this assorancur, I at asking the Of fice cf Resource Manageeent to proceed with issuance of the enclosed version of the e.ar.wa l enapter.
At the October 10 and 11 Management meeting, IE coeritted to convene a revtem group to aodress further chan9es that may be needed to the SALP process.
Alsc, an asettional issue concerning SALF has recently surfacec.
This 1ssee is related to Commissioc actions with respect to licensee training programs in rescense to Section 306 of the nuclear Waite Policy Act.
Consideration is being given to including training as a separate area to i,e addressed in all SAJ reports.
To address new and remaining issues, we will make arrangements t
'er a meeting of the resiew group in the near future. We have contacts for all tr.e Regtoes ane Headgaarters Offices anc will be talking with ther to set up the necting.
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o U.S. NUCLEAR REGULATORY COMMISSION NRC MANUAL j
Volume: 0000 General Administration Part:
0500 Health and Safety IE CHAPTER 0516 SYSTEMATIC ASSESSMENT OF LICENSEE'PERFORl:ANCE 0516-01 COVERAGE
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This Chapter and 'its appendix describe the basic structure and overall procedures for implementation of the NRC program to assess licensee perform-ance.
This program applies to all. power reactors with operating licenses or construction permits (hereinafter referred to as licensees).
0516-02 OBJECTIVES 021 To improve the NRC regulatory program.
022 To permit sound decisions regarding HRC resource allocations.
023 To improve licensee performance.
024 To collect availabic observations on a periodic basis and evaluate licensee performance based on those observations, through the Systematic Assessment of Licensee Performance (SALP), an integrated NRC staff effort.
Positive and negative attributes of licensee performance are considered.
Emphasis is placed upon understanding the reasons for licensee's perform-ance in important functional areas, and sharing this understanding with the licensee. The SALP process is oriented toward furthering NRC's under-standing of the man.1er in which:
(a)thelicenseemanagementdirects, 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 diagnostic to provide a rational basis for allocating HRC resources to provide meaningful guidance to licensee management.
0516-03 RESPONSIBILITIES AND AUTHORITIES 031 The Executive Director for Operations (EDO) provides oversight for the activities described herein.
Aphroed:
SYSTEMATIC ASSESSMENT OF i
0516-032 LICENSEE PERFORMANCE f
032 The Director. Office of Inspection anti FnEnrcement (IE):
a.
Implements the requirements of this chapter within the Office of Inspection and Enforcement.
b.
Monitors the SALP process; evaluates and develops SALP policy, criteria, and methodology; and assesses the uniformity and adequacy of the regions' implementatioh of the program.
033 The Directors, _0ffices of Nuclear Reactor Regulation (NRR),
Analysis and Evaluation of Operational Data (AEOD), and Nuclear Materials Safety ano Safeguards (NMSSh Amplement the require-ments of this chapter within their Ofhces.
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034 Regional Administrators ;
a.
Implement the requirements of this chapter within the
- Regions, b.
Ensure that assessments of licensee nuclear safety perfor-mance are conducted.
determine when a meeting with the licensee is necessary to c.
assure mutual understanding of the issues discussed in the SALP Board report.
i d.
Evaluate the SALP Board report and the licensee's comments; provides a characterization of overall safety performance; formally issues the NRC SALP report; follows up on licensee comitments; and reallocates region inspection resources as j
appropriate.
e.
Provide to the Director, Office of Inspection and Enforce-ment, recommendations for improvements to the SALP program i
and coments on proposed changes to SALP policy.
t 0516-04 EVALUATION CRITERIA AND FUNCTIONAL AREAS 041 Evaluation.
Licensees will be evaluated in the functional areas 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 a 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 review. If a functional area appropriate to a licensee is not covered, the reasons should be given in the report. The Appendix to this Chapter lists a number of attributes for each evaluation criterion.
l The functional area being evaluated may have some attributes that would place the evaluation in Category I and others that would place it in either Category 2 or 3.
The final rating for each functional area will be a composite of the attributes tempered with judgment as to significance of individual items. Departures
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. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-04/
from this guidance may sometim s be warranted.
In such cases, the rationale for such departures should be erpleineri in the report.
042 Functional Areas. A grouping of similar activities.
a.
Operating Phase Reactors 1.
Plant Operations Consists chiefly of the activities of the licensee's operational staff (e.g., licensed operators, shift technical advisors, and auxiliary operators).
It is intended to be limited to operating activities such as plant startup, power operation, plant shutdown, and system lineups. Thus, it includes activities such as reading and logging plant conditions; responding to off-normal conditions; manipulating the reactor and auxiliary controls; and training / retraining of licensed operators, shif t technical advisors, and auxiliary i
operators.
2.
Radiological Controls Includes controls 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; radiological effluent and environmental monitoring; and the results of the NRC's independent measurement program.
3.
Maintenance i
Includes all activities associated with preventive or corrective maintenance of instrumentation and control equipment and mechanical and electrical systems.
4.
Surveillance Includes all surveillance testing activities as well as all inservice inspection and testing activities.
Examples of activities included are:
instrument cali-brations, equipment operability tests, containment leak rate tests, special tests, inservice inspection and performance tests of pumps and valves, and all other inservice inspection activities.
5.
Fire Protection Includes routine housekeeping and fire protection /
prevention program activities. Thus, it includes the storage of combustible material; fire brigade staffing Approved:
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_. 7 SYSTEMATIC ASSESSMENT OF 0516-042 LICENSEE PERFORMANCE p
9 and training; fire suppression system maintanence and operation; and those fire protection features provided for structures, systems, and components important to safe shutdown.
6.
Emergency Preparedness Includes activities relating to the implementation of the emergency plan and implementing procedures. Thus, j
it includes such activities as licensee's performance during exercises which test the licensee, state, and local emergency plans; plan administration and implemen-tation; notification; communications; facilities and equipment; staffing; training; assessment; emergency classification; medical treatment; radiological exposure control; recovery; protective actions; and interfaces with onsite and offsite emergency response organizations.
7.
Security i
Includes all activities whose purpose is to ensure the security and continued operability of the plant.
Specifically it includes all aspects of the licensee's security program (e.g. access control, security checks, l
badging).
l 8.
Refueling Includes all activities associated with refueling.
4 I
Thus, it includes outage management, and the manipu-j lation of new and spent fuel.
l 9.
Quality Programs and Administrative Controls Affecting Quality j
Includes all verification and oversight activities which j
affect or assure the quality of plant activities, structures, systems and components. This area may be i
viewed as a comprehensive management system for con-l trolling the quality of work performed as well as the quality of verification activities 'that confirm that I
the work was performed correctly. The evaluation of the effectiveness of the quality assurance system should be based on the results of management actions to ensure that necessary people, procedures, facilities j
and materials are provided and used during the opera-1 tion of the nuclear power plant.
Principal emphasis i
should be given to evaluating the effectiveness and i
involvement of management in establishing and assuring the effective implementation of the quality assurance program along with evaluati'ng the history of licensee i
performance in the key areas of:
comittee activities, design and procurement control, control of design i
Approved:
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-04L4 change processes, inspections, audits, corrective action systems, and records.
- 10. Licensing Activities Includes the adequacy and timeliness of all licensing submittals, responsiveness to NRC licensing initiatives, and the licensee's approach to res61ution of technical issues from a safety standpoint.
II. Others (As Needed) b.
Construction phase Reactors 1.
Soils and Foundation Includes all 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, embankments, f oundations and associated laboratory testing, instrumentation and monitoring systems.
2.
Containment, Safety-Related Structures, and Major Steel Supports 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., reinforcing 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, pressurizer, polar crane, tanks, heat exchangers, etc.).
3.
Piping Systems and Supports Includes those safety-related piping systems described in 10 CFR 50.2(v) and R.G.1.26, quality groups A, B and C.
It is intended to be limited to the primary pressure boundary and other safety-related water, 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 for these systems.
The primary inspection emphasis in this area is on piping systems and their supports / restraints.
Approved:
SYSTEMATIC ASSESSMENT OF 0516-041.b. 4 LICENSEE PERFORMANCE 4.
Safety-Related Components - Mechanical Covers mechanical components such as pressure vessels, pumps, and valves located in, and attached to, the piping systems described in 3 above.
The primary emphasis here is on components rather than piping.
5.
Auxiliary Systems 4
I includes those safety-related auxiliary systems included in the nuclear facility which are essential for the safe 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 Eauipment and Cables Includes safety-related electrical components, cables and associated items used in the electrical systems of the plant, such as: motors, transformers, batteries, i
emergency diesel generators, motor control centers, switchgear, electric raceways, cable (power, control, and instrument), circuit breakers, relays and other interrupting and protective devices.
7.
Instrumentation I
Covers safety-related instrument components and systems i
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 two plant systems utilizing such devices as:
sensors, transmitters, signal con-ditioners, controllers and other actuating devices, recorders, alams, logic devices, instrument taking, air supplies, racks and panels.
8.
Quality Programs and Administrative Controls Affecting
_ Quality I
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 i
comprehensive management system for controlling the quality of work performed as well as the quality of verification activities that confinn that the work was perfonned correctly. The evaluation of the effectiveness of the quality assurance system should be based on the results of management actions to ensure that necessary people, procedures, facilities and materials are provided and used during the design and construction of the nuclear power plant.
Principal emphasis should be Approved:
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SYSTEMATIC ASSESSMENT OF o
LICENSEE PERFORMANCE 0516-042.c r
I given to evaluating the effectiveness and involvement of
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management in establishing and assuring the effective implementation of the quality assurance program 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.
Licensing Activities 4
l Includes all activities supporting the NRC review of the application for and the issuance of the Construc-tion Pemit and Operating License, and amendments thereto.
In addition, it includes the adequacy and timeliness of all licensing submittals, responsiveness to NRC licensing initiatives, and the applicant's or f
licensee's approach to resolution of technical issues from a safety standpoint.
10.
Others (As needed) c.
Preoperational Phase Reactors 1.
Preoperational Testing l
Covers the preparation, conduct, and evaluation of test results for preoperational tests performed by or under the direction of the licensee's staff to demonstrate the proper functioning and conformance to design requirements of components, systems, and structures.
2.
Others (As Needed)
For reactors in the preoperational phase, functional areas from the listing for either operating phase reactors or construction phase reactors should be selected as appropriate, d.
Startup Phase Reactors i
1.
Startup Testing l
Covers the preparation, conduct, and evaluation of test 9
l results for testing conducted following the issuance of i
the operating license.
It starts with initial fuel loading and precritical tests, and continues until the plant reaches cornercial operating status at or near j
its licensed power rating.
2.
Others(AsNeeded) l For reactors in the startup phase, functional areas l
Approved:
SYSTEMATIC ASSESSMENT OF OS16-04I LICENSEE PERFORMANCE from the listing for epcrating phase rc ctors should be used.
043 Performance Categories.
A rating of licensee performance in a given functional area, a.
Category 1 Reduced NRC attention may be appropriate. Licensee management attention and inv.olvement 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.
Category 2 NRC attention should be maintained at normal levels.
Licen-see management attention and involvement are evident and are concerned with nuclear safety; licensee resources are ade-quate and reasonably effective so that satisfactory perfom-ance with respect to operational safety or construction is being achieved.
c.
Category 3 Both NRC and licensee attention should be increased.
Licen-see management attention or involvement 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 operational safety or construction is being achieved.
044 Trend. The general or prevailing tendency (the perfomance grad-ient) over the course of the SALP assessment period.
The deter-mination of the trend should not be forced.
In those instances where a prevailing trend can 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.
Improved Licensee perfomance has generally improved over the course of the SALP assessment period.
b.
Same Licensee perfomance has remained essentially constant over the course of the SALP assessment period.
c.
Declined 4
Licensee perfomance has generally declined over the course Approved:
k SYSTEMATIC ASSESSMENT OF l
LICENSEE PERFORftANCE 0516-045 pf the SALP assessment perjod.
045 Evaluation Criteria. Elements which must be considered when assessing a licensee's performance in a functional area.
a.
The evaluation criteria are as follows:
1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint l
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 using these criteria to arrive at a category assignment is found in the Appendix to this Chapter.
1 0516-05 BASIC REQUIREMENTS l
051 Applicability.
This Chapter applies to and shall be followed by NRC Headquarters Offices and Regional Offices.
052 Appendix 0516.
Procedures for implementation of these directives are presented in the Appendix to this Chapter.
i e
i Approved:
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SYSTEHATIC ASSESSMENT OF i
LICENSEE PERFORMANCE NRC APPENDIX 0516 i
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APPENDIX a
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4 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE i
I i
i UNITED STATES NUCLEAR REGULATORY C0lHISSION OFFICE OF INSPECTION AND ENFORCEMENT i
e 9
I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 I
i CONTENTS Page PART I GENERAL.....................
I PART II EVALUATION CRITERIA...............
3 PART III SALP BOARD ASSESSMENT..............
11 PART IV MEETING WITH LICENSEE..............
17 PART V ISSUANCE OF REPORT 19 PART VI APPENDIX TO THE SALP REPORT...........
21 PART VII FORMAT FOR SALP REPORT 23 FIGURES FIGURE 1 SALP EVALUATION PROCESS.............
2 TABLES Page TABLE 1 Evaluation Criteria With Attributes for Assessment of Licensee Performance 5
TABLE 2 Evaluation Matrix for Operating Phase Reactor Functional Areas 13 TABLE 3 Evaluation Matrix for Construction Phase Reactor Functional Areas 15 EXHIBITS EXHIBIT I -
Examples of Overall Safety Perforrance Characterizations................ 24 EXHIBIT 2 -
SALP Boa rd Report..............
25 EXHIBIT 3 -
An Erra ta Sheet...............
35 EXHIBIT 4 -
Original Page................
36 EXHIBIT 5 -
Corrected Page 37 i
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART I PART I GENERAL A.
The SALP program was established to improve the 'sRC Regulatory Program, to permit sound decisions regarding NRC resource allocations, and to better understand the reasons for the performance of each reactor licensee.
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.
l.' hen the Regional Administrator determines that a particular utility or facility should be evaluated more frequently; or
}[ hen a SALP Report will be used as part of an evaluation of 2.
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 assessments are intended to take place at an approximately uniform rate throughout the year within each Regional office.
C.
The evaluation process is composed of (Figure 1, Part I):
1.
A SALP Board assessment; 2.
Issuance of the SALP report; 4
3.
If requested by the licensee or if otherwise determined to be necessary by the Regional Administrator, a meeting with licensee management to discuss the assessment; and 4.
Consideration of any written coments received from the licensee and issuance of an appendix to the SALP report which is to i
include the verbatum written commer.ts received from the licensee and the conclusions of the Regional Administrator on the basis of his consideration of the coments.
Procedures for implementing the SALP program are provided in this Appendix.
1
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORHANCE PART II HGURE 1.
SALP Evaluation Process SALP Board Preparation (PartIII)
SALP Board Meeting (PartIII)
SALP 1
Report Issuance i
(PartV)
Meeting with the Yes Licensee?
No Meeting with the Licensee (PartIV) l Licensee Responds Appendix to the SALP Report (PartVI) i 2
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART II PART II' EVALUATION CRITERIA The assessment of licensee performance is implemented through the use of seven evaluation criteria. The criteria provide standard guidance that shall be applied to each functional area for the categorization of licensee performance.
To provide consistent evaluation of licensee performance, several attri-butes associated with each criterion are listed to describe the character-istics applicable to the three categories.
The seven criteria discussed in Chapter NRC-0516-045 are listed in Table I with their associated 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-sideration of these attritates influence established programs of the agency. For example, it is not inten.ded 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-tional area may be insufficient to allow consideration in the evaluation.
Conversely, additional attributes may be appropriate for the evaluation.
Matters such as management involvement and training are criteria of each 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 problem in Plant Operations, Radiological Control and Surveillance.
It would be appropriate to discuss training as if it were a functional area, in addition to covering the specific training problem in each functional area.
It is emphasized that all available information should be analyzed by the SALP Board, and its significance, whether it be positive or negative, should be weighed.
If information is scarce or nonexistent, a decision regarding the perfonnance category or trend as it relates to an attribute should not be forced.
l 3
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A'Q TABLE 1 EVALUATION CRITERIA WITil ATTRIBUTES FOR ' ASSESSMENT OF LICENSEE PERFORMANCE 5i':2
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Category 1
' Category 2 Category 3 g
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Management involvement and Control in Assuring Quality
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consistent evidence of prior evidence of prior plannin little evidence of prior planning and assignment of assignment of priorities;g and planning and assignment of priorities; well stated,
.'sta ted defined procedures for priorities' poorly stated or controlled and. explicit control of activities
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procedures for control of control.of activities
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activities j
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well stated, diss s.;cated,.and adequately stated and poorly stated, poorly understandable policies understood policies understood or nonexistent policies
,pp decisionmaking consistently at decisionmaking usually at a decisionmakfng seldom at a a level that ensures adequate level that ensures adequate level that ensures adequate management review management review management review corporate management frequently
' corporate management usually corporate management seldom x
involved in site activities involved in site activities involved.in site activities M
z audits complete, t.imely, and audits generally complete, audits frequently not timely, E
thorough timely, and thorough incomplete, or not thorough mE gx
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Category 1 Category 2 Category 3
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5.
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Management Involvement and Control in Assuring quality (Continued)
M
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4 committees properly sta,ffed and, _ committees usually properly '.
w committees not functioning in almost all cases stafred and functioning or functioning, prop.drly staffed reviews timely, thorough, and reviews generally timely,
, reviews not timely, thorough, e.2.c technically sound
, thorough, and technically. sound
, r technically sound o
records complet'e, well.
records generally complete -
..-;,,lljrecords not complete, not well ij
.gJ.V maintained, and available well maintained, and available !'j, maintained, or unavailable
- i procedures and policies procedures and policies rarely procedures and policies strictly adhered to violated
. occasionally violated
~
corrective action sys'tems corrective action systems corrective action systems d
promptly and consistently generally recognize and address rarely recognize and address recognize and address nonreportable concerns nonreportable concerns.
nonreportable concerns procurement well controlled and procurement generally well repetitive breakdown in O
documented, controlled and documented procurement, control M
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design well controlled and rare breakdowns of minor repetitive breakdown in design jim verified significance in design coittrol control or verification LT r
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.. C4 Category 1 Category 2 Category 3 A"
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Approach to Resolution of Technical Issues from a Safety Standpoint oM O
g
. s om clear understanding of issues understanding of issues understanding of issues :
?' G demonstrated generally apparent frequently lacking !
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m5 conservatism routinely conservatism generally; meets minimum requirements
- 5i?
exhibited when potential for exhibited safety significance exists technically sound and thorough viabic and generally sound and of teri viable approaches; but approaches in almost all cases thorough approaches lacking in thoroughness or depth m
timely resolutions in almost generally timely resolutions resolutions of ten delayed all cases 3.
Responsiveness to NRC Initiatives meets deadlines generally timely responses frequently requirbs extensions of time timely resolution of issues few longstanding regulatory longstanding regulatory issues' M
issues attributable to licensee attributable to licensee g
n 5
~4 O bM 4
g a
T 3*
I Category 1 Category 2 Category 3 3;M-u
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3.
Responsiveness to NR0 Initiatives (Continued) y S
x technically sound and thorough " ' viable and generally sound a.nd often viable responses, but g
responses in almost all, cases thorough responses lacking in thoroughricss. or depth acceptable resolutions proposed acceptable resolutions considerable NRC effort or initially in most cases
. generally proposed repeated submittals needed to obta.in. acceptable resolutions I
4.
Enforcement IIistory majorviolationsarerareand majorviolationsarerareand multiple major violations or are not indicative of may indicate minor programmatic programmatic breakdown
't programmatic breakdown breakdown indicated minor violations are not multiple minor violations or minor violations are repetitive repetitive and not indicative minor programmatic breakdown and indicative of programmatic of programmatic breakdown indicated breakdown w
corrective action is prompt and corrective action is timely and corrective action is delayed or ef fective '
effective in most cases not effecti~ve Ct R8 SM A
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'em Category 1 Category 2 Category 3 M
gm, mf 5.
Reporting and_Analys.ts of Reportable Events "g
m events are promp 1 and E' events are reported in a timely event reportin 'is frequently
,,_ manner, some information may he late or incompfete ;'
hm completely repor e lacking q
o events are properly identified events are accurately events are poorly identified or and analyzed identified, some analyses are analyses are marginal, events inarginal are associated with programmatic weaknesses corrective action is effective, corrective action is usually.
corrective action is not timely.
as indicated by lack of taken but may not be effective, nor effective, events are repetition as indicated by occasional repetitive j'
repetition 6.
Starfing (Including' Management)_
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positions are identified, key positions are identified, positions are poorly authorities and
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go 6.
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~_
7.
Training and Qual'ification Effectiveness a
training and qual.ification training and qualification training and qualification program makes a positive progran contributes to an program is found to be the contribution,d starring, to commensurate with adequate understanding of major contributing factor to procedures an work and fair adherence to
.peor understanding of work, as.
understanding of work and procedure with a modest number indicated by numerous procedure adherence to procedures with of' personnel errors violations or personnel errors few personnel errors W
training program is well a defined program is program may be either lacking, D
defined'and implemented with impicmented for a large portion poorly defined, or Cy dedicated resources and a means of the staff ineffectively applied for a
@d for feedback experience; significan.t' segment of the N, o program is applied to nearly staff g
r all staff gp
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N 9
i 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 meeting, if necessary, for all facilities within the Region for all SALP meetings to occur in the calendar year.
This memorandum shall be sent to NRR, IE, NMSS, AEOD, ano the EDO by the end of the preceding calendar year. SALP Board members will be notified promptly of any unavoidable chenges.
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 sta'te that fact to the Region by memorandum.
b.
Prepare the Supporting Data Summary section of the report.
(See Part VII, Exhibit 2 for format.)
c.
Prepare a performance analysis for each of the functional areas identified in NRC 0516-042.
(See Part VII, Exhibit 2 forformat.)
B.
SALP Board Meetina 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:
a.
SALP Board Chairman (Branch Chief or above) b.
NRR Project Manager c.
NRR management representative (participation is further described in NRR Office Letter 44, January 3,1984) d.
Senior Resident Inspector e.
Representatives from IE, AEOD, and NMSS as determined by the respective Office Director.
f.
Other individuals as determined by the Regional Administrator 11
NRC 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 conclusion regarding licensee performance or alternatively confirm that suffi-cient information is not available to support a conclusion regarding licensee performance.
b.
. Rate licensee performance in each functional area after considering the evaluation criteria with their associated attributes listed in Table 1 of Part II of this appendix.
Tables 2 and 3 may be used by the SALP Board members to assist them in their rating of a licensee.
c.
Recommend changes to the inspection program emphasis, as necessary.
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SYSTEMATIC ASSESSHENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART IV PART IV-NEETING WITH LICENSEE A.
General.
If requested by the licensee or if otherwise determined to be necessary by the Regional Administrator, a meeting with licensee management to discuss the assessment will be held.
B.
Meeting Preparation 1.
Notification of the meeting (if held) should be made by the Region at least one month in advance. Hotification should be made to the licensee, the resident inspectors at the involved facilities, the NRR Project Managers for the involved facilities, and cognizant HRC managers.
2.
The licensee should be encouraged to have the following manage-ment representatives participate in the meeting.
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 C.
Meetina with Licensee 1.
The meeting (if held) should be conducted within 90 days after the end of the assessment period.
2.
NRC representatives for this meeting should include the following:
a.
Either the Regional Administrator, Deputy Administrator, or Division Director l
b.
Responsible Regional Division Director (s), Branch Chiefs, or Section Chiefs, as appropriate c.
NRR Project Manager and designated HRR manager j
d.
Resident Inspector and/or assigned inspectors J
e.
Public Affairs Officer, when media interest is anticipated 3.
The Regional Administrator, Deputy Administrator, or Division Director will chair the meeting and discussions of the adequacy of the licensee's management controls.
These meetings are intended to provide a forum for candi.d discussion of issues relating to the licensee's performance. Those aspects of the licensee's operation that need improvement will be identified.
17 1
' NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART IV LICEllSEE PERFORMANCE The licensee will also be given the opportunity to make comments on the report in writing within 30 days after the meeting or receipt of the SALP Board report if no meeting is held.
Only written comments from the licensee must,be addressed by the
~
Regional Administrators.
4.
SALP management meetings with the licensee should be conducted as open meetings, with the exception of those portions of the meetings that involve discussion of matters not required to be mandatorily placed in the public domain pursuant to 10 CFR 2.790.which must be closed.
Members of the public 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 appropriate docket.
e i
18
' SYSTEMATIC ASS'ESSMENT OF HRC APPENDIX 0516 LICENSEE PERFORMANCE PART V
~
PART V ISSUANCE OF REPORT A.
Issuance of Report The SALP Board Report (Exhibit 2, Part, VII) shall be transmitted by the Regional Administrator to the licensee with copies to NRR and IE.
The transmittal letter should include:
1.
A request for licensee's written comments and amplification, as appropriate, on these comments within 30 days after the meeting (if held) or receipt of the SALP Board report. The licensee's response should include, as a minimum, corrective actions to be taken in functional areas rated Category Three.
2.
Ainplification 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 3,PartVII);and 3.
A characterization of overall safety performance.
This letter, enclosing the SALP Report, will receive standard docket distribution including the HRC Public Document Room and the local Public Document Room, and INP0 (Record Center, IHP0; 1100 Circle 75 Parkway; Suite 1500; Atlanta, GA 30339).
Each report will be assigned an Inspection Report number.
B.
Chanoino the SALP Report 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).
a.
Include an errata sheet (Exhibit 3, Part VII) as a separate en-closure to a Regional Administrator'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.
Make a diagonal line through the original page, referencing the Errata sheet.
19
)
SYSTEMATIC ASSESSMENT OF HRC APPENDIX 0516 LICENSEE PERFORKANCE PART VI PART VI.
APPENDIX TO THE SALP REPORT A.
General After receiving the licensee's written comments,'the Regional Administrator shall, issue an appendix to the SALP report within 30 days.
This appendix will receive standard docket distribution including the HRC Public Document Room, the local Public Document Room and INP0.
B.
Appendix to the SALP Report The appendix to the SALP report shall consist of:
t 1.
The verbatim written comments received from the licensee; 2.
A summary of any meetings held with the licensee concerning the SALP report; and i
3.
The conclusions of the Regional Administrator on the basis of his consideration of the licensee's comments.
I l
l I
l l
l i
21 I
j SYSTEMATIC ASS'ESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART VII i
PART VII SALP REPORT FORMAT AND CONTENT A.
General The SALP Board report is considered to be a final report upon approval by the Board and dispatch to the licensee.
B.
Multiple Facility Licensees In cases such as Duke and Commonwealth Edison, the SALP package nay address more than one site. However, each site should have a separate SALP Bbard Report (Exhibit 2, Part VII).
.C.
Report Format 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, 1
23
. NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART VII LICDiSEE PERFORitANCE
~
EXHIBIT 1 1
1 Samples of Overall Safety Performance Chacterizations I
f Example 1 Overall, we find that your performance of licensed activities generally is acceptable and directed toward safe facility operation.
In addition, your j
overall performance has showed only moderate improvement since the last SALP evaluation period. Your performance in the area of Plant Hodifications with contractors having limited experience was found to be in need of increased management attention.
(
Exampie 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 evident that safe operation and compliance with regulatory requirements are f
priority considerations at your facility.
I concur, however, with the SALP Board findings that management attention is required to correct problems in i
the area of Radiological Controls and the long standing problems associated with the existing perimeter alarm system.
Example 3 i
i The overall performance of your facility was acceptable but exhibited a declining trend since the last SALP evaluation period. Resources were strained or not effectively used such that minimally satisfactory perform-ance with respect to operational safety was achieved. The SALP Board identified weaknesses in the areas of plant operations, radiological controls, maintenance, security and safeguards, and the quality assurance program.
Your performance in these areas will be closely monitored and discussed in the next SALP Board Assessment for your facility.
A major strengh.was noted in the area of refueling.
Eyample'4 Overall, we found your performance acceptable and directed toward safe facility operation.
In addition, we found your overall performance im-proved since the last SALP evaluation period. We found agressive manage-ment attention and a high level of performance in the following areas:
Radiological Controls, Surveillance, Fire Protection and Housekeeping, Emergency Preparedness, and Refueling. Your performance in assuring that equipment and procedural changes and adequately controlled was found to need increased attention on your part and we will pay particular attention to this area during our subsequent inspections.
24
ilRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORitANCE
~
EXHIBIT 2 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION REGION [ region]
SYSTD!ATIC ASSESSiiENT OF LICENSEE PERFORMANCE
[ Inspection Report Nunber]
[NameofLicensee]
[NameofFacility]
[AssessmentPeriod]
I 25
' HRC APPENDIX O'516 SYSTEMATIC ASSESSMENT OF PART VII LICEriSEE PERFORPANCE EXHIBIT 2 (C nt'd)
I.
INTRODUCTION The Systematic Assessment of Licensee Perfomance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this infomation. SALP is supplemental to nomal regulatory processes used to ensure compliance to Hr.C rules and regulations..
SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operation.
A tiRC SALP Board, composed of the staff members listed below, met on
[date],toreviewthecollectionofperformanceobservationsanddata to assess the licensee perfomance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Perfomance."
A sumhry of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety performance at [name of facility] for the period [date] through [date).
SALP Board for [name of facility]:
[ListSALPBoardMembers]
a 26
7 4
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0156 LICENSEE PERFORMANCE PART VII EXHIBIT 2 (Cont'd)
II.
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 normal programmatic areas.
Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations. Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement and control in assuring quality 2.
Approach to resnlution of technical issues from a safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management) 7.
Training effectiveness and qualification However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories.
The definition of these performance categories is:
Category 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.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieved.
27
NRC APPENDIX 0516 SYSTEIMTIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE EXHIBIT 2 (Co'nt'd)
Catecory 3.
Both NRC and licensee attention should be increased.
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-factory performance with respect to operational safety or construction is being achieved.
III. SUICMRY OF RESULTS
[ Provide a narrative summary of the licensee's overall significant strengths and weaknesses.
It should be similar to the overall performancenarrativeusedinthelettertothelicensee.]
Functional Area
[lastperiod]
fthis period]
Trend
[ functional area]
. [ratinglast
[ rating this
[ trend]
period]
period]
IV.
PERF0PJMNCE ANALYSIS A.
[ Functional Area being discussed]
1.
Analysis
[The analysis of the licensee'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 presented in a manner to place matters in perspective and to allow the reader to understand the rationale for stated conclusions. This analy-sis should concentrate on the adequacy of the licensee's management control systems, adequacy of resources, 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 with the attributes of each category.
The attributes listed in Part II are specifically oriented toward this 28
SYSTEllATIC ASSESSHENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART VII e
EXHIBIT 2 (Co'nt'd) l I
and should be utilized.
In no event, however, are the examples of licensee performance for specific attributes to be used as stand-alone assessments; they represent a sampling of possible conclusions which must be supported by, appropriate facts, observations or analysis.
Each analysis should be written to avoid either 10 CFR 2.790 or safeguards information.
The analysis section is composed of three major subsections:
l A brief account of the inspection activity which occurred in this area.
j A brief summary 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 summary of the strengths, weaknesses, and other significant observations made by the NRC staff during theevaluationperiod.]
2.
Conclusion f
r
[ Provide the performance assessment (Category 1, 2, or 3) and trend (Improved, Same, Declined) for each functional area considered and if appropriate, a sunmary assessment.]
3.
Board Recommendations
[ Recommend NRC actions to be taken, if any are required. A basis for changes in the NRC program must be provided. Note that even in the absence of a recommendation to vary inspec-i tion levels, the Regional Office may do so based on the i
assessment as discussed in appropriate chapters of the IE nanual.]
i i
f I
'I I
I 29 ww w
NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART Vll LICENSEE PERFORMANCE EXHIBIT 2 (Cont'd)
V.
SUPPORTING DATA AND SU MARIES A.
Licensee Activities
[ Provide an outline of major licensee activities, such as major
- outages, power limitations, important licensee amendments, and significantmodifications.]
B.
Inspection Activities
[ Provide a sum.ary of major inspection activities in each functional a rea.
This is not intended to be a summary of each routine inspection performed, but rather a summary of major inspection activities such as team inspections.
Include Table 1.]
C.
Investigations and Allegations Review
[ Provide a sumary of major investigative activities and their results.]
D.
Escalated Enforcement Actions a.
Civil Penalties [ Provide a sumary]
b.
Orders (only these relating to enforcement) [ Provide a sum.a ry]
E.
Management Conferences Held During Appraisal Period Conferences [ Discuss conferences that dealt with regulatory a.
performance or enforcement.]
b.
Confirmation of Action Letters [ Provide a sue.ary]
[0ther]
[ Discuss any other issues at the discretion of the SALP Board.]
F.
Review of Licensee Event Reports, Construction Deficiency Reports, and 10 CFR 21 Reports Submitted by the Licensee
[ Provide a brief sum.ary of significant findings and trends j
resulting from a review of these reports. If this information is contained in another section of the report, this item may be omitted.]
30
NRC APPENDIX 0516
.., SYSTEMATIC ASSESSMENT OF PART VII LICEfiSEE PERFORI!ANCE EXHIBIT 2 (Cont'd)
TABLE I INSPECTION ACTIVITY AND ENFORCEMENT NO. OF VIOLATIONS Ill EACH SEVERITY LEVEL FUNCTIONAL AREA V
IV III II I
I e
TOTAL 31
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART VII EXHIBIT 3 AN ERRATA SHEET SALP BOARD REPORT ERRATA SHEET PAGE LINE NOW READS SHOULD READ 5
24 operator's cognitive decision 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 mean that.the operator as the cognizant individual on shif t knew the operating requirements of the Technical Specification but made a conse.ious decision to operate the plant in a manner which he felt was equiv-alent to the requirements. It was not intended to mean that the operator took actions in total disregard of the Technical Specification objectives.
32
' NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF
,,,_PART Vil LICENSEE PERFORMANCE 3
EXHIBIT 4-ORIGINAL PAGE (10)
Severity Level IV - Failure to take timely and proper corrective action following the failure of a cold leg RTD (50-000/81-24).
F Severity Level VI - Failure to make'a 30 day report on a " degraded 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 failure to follow procedures, and one for incomp'ete documentation.
One noncompliance for failure to properly report a br ch in~ containment, Item (9) above, is part of an escalated enforcement a tion 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 at Unit I and three t Unit 2.
Sixty percent of these occurred in the last half of the peri and thirty percent in the last quarter indicat-ing an increasing occur nce rate in the period.
Six of the nine were for incorrect valve or b aker alignments and three were for failure to follow operating procedure e
Two events (LER's 50-000/81-6/ %d 50-000/81-52) were of particular concern since they rcflected a
- ansed operator's cognitive decision to operate a system (charging and les en a'nd containment isolation, respectively) in a manner not allow # g the Technical Specifications.
Unit 1 experienced nine automatic t t, 'eE g ing the evaluation period, four caused by errors, two were due to. equipment, f ailure. Of the four caused by operator error and five i
trectly conducted instrumen' surveillance tests, one to an incorrect v lineup on the steam side, and the last to unfamiliarity vith turbine
+rols.
Unit 2 experienced nine reactor trips, one beir manually initiated turbine trip.
Four of the trips were related to ; sonnel errors; two by loss of vacuum in the ' main condenser, one resul from a low steam generator level, and one resulted from a turbine va misalignment.
'No significant safety concern is associated with these tr' s and each was reviewed to verify proper safety system operation and erator actions.
Various operating problems and events identified during the peri d resulted in an enforcement meeting on August 4,1981, with follow meeting on August 4,1981, with followup meetings on November 2,19 5
9
m.--
2---
'
- S.YSTEMATIC ASSESSMEh7 0F NRC APPENDIX 0516
}.,(, LICENSEE PERFORMANCE PART VII EXHIBIT 5-CORRECTED PAGE (10)
S erity Level IV - Failure to take timely and proper corrective action following the failure of a cold leg RTD (50-000/81-24).
(11)
Severity Level VI - Failure to make it 30 day report on a -degraded bus voltage ' relay (50-000/81-26).
Six of the noncompliances.were for failure to mne required reports or to make timely reports, four for failure to follow procedures, and one for incomplete documentation.
One noncompliance for failure to properly report a breach in containment, Item (9) above, is part of an escalated enforcement action with Civil Pennity.
The actual event, is described in Section 4, Surveillance.
Nine LER's relating to this area were 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 thirty percent in the last qua-ter 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 i
follow operating procedures, f
Two events (LER's 50-000/81-67and50-000/01-52) were of particular i
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.
Unit 1 experienced nine automatic trips during the evaluation period, four caused by operator error and five by equipment. failure.
Of the f6ur cau' sed by errors, two were due to incorrectly conducted instrument surveillance tests, one to an incorrect valve lineup on the steam side, and the last to unfamiliarity with turbine controls.
Unit 2 experienced nine reactor trips, one being a manut.lly initiated turbine trip.
Four of the trips were related to personnel errors; two by loss of vacuum in the. main condenser,, one resulted from a low steam generator level, and one resulted from a turbine valve misalignment.
No significant safety concern is associated with these trips and each was reviewed to verify ' proper safety system operation and operator actions.
Various operating problems and events identified during the period resulted in an enforcement meeting on August 4,1981, with followup meeting on August 4,1981, with followup meetings on November 2,1981 5
J W -'
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K'm.ACLltEQUESTOOM
- ' 3
""5 Fora 5%
US Nuclear Regulatory Commission g'k lOfN
. Region Til 799 Roosevelt Road Glen Ellyn IL. 60137 To Whom It May Concern:
L'nder the Freedom of Inforestion Act I am requesting documents that pertain to Region TTI USNRC Business for 1985.
Please, supply the following:
A.
One copy of the USNRC Region TIT Operating Plan B.
One copy of the USNRC SALP Rnting Guide for Operating Reactors-that Region TIT will use for doing 1985-86 evaluations The address to which this materini may be ment is:
LJKenaga 09937 Kannian Ct.
South Haven. MT. 49090 Your cooperation in appreciated.
- Sinc,arely,
f.Then O c(
l 1
IC0585-0022A-EP02 i.'WAY:
919R5