ML20141A235
| ML20141A235 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/1985 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Jennifer Davis, Harold Denton, Stello V NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20140A422 | List: |
| References | |
| NUDOCS 8511070508 | |
| Download: ML20141A235 (45) | |
Text
.
UNITED STATES Oh E
NUCLEAR REGULATORY COMMISSDN
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f n( fc 'epua November 5,1985
/
r MEMORANDUM FOR:
Those on Attached List FROM:
James M. Taylor, Director Office of Inspection and Enforcement
SUBJECT:
PROPOSED CHANGES TO THE SALP MANUAL CHAPTER (NRC 0516)
A November 15, 1984 memorandum from Richard C. DeYoung fomarded for interim guidance and implementation a revision to the SALP Manual Chapter (NRC 0516).
Mr. DeYoung's memorandum also stated that a review ~ group would be convened to address further changes to the SALP process. The review group developed additional proposed changes to NRC 0516 which were incorporated into a pro-posed revision to NRC 0516.
That proposed revision was forwarded to you as an enclosure to nty June 27, 1985 memorandum.
Your comments on that proposed revision were considered and used as appropriate to prepare the enclosed revision to NRC 0516. The enclosed revision reprc-sents current NRC policy and practice and should therefore be implementeo s soon as possible without interrupting SALPs currently in progress.
Concurmatly, I am also fomarding a copy of the enclosed NRC 0516 to the Office of Raource Management and requesting that they proceed with its issuance.
Based on comments received, the enclosed revision to "RC 0516 includes the following major changes from the proposed revision dit 'ributed on June 27, 1985:
Deletion of the requirement to address trend "or each functional area. The enclosed revision to NRC 0516 prov: des for the SALF Board to include, as a Board coment, an appraisal of the licea-see's performance trend in a functional area when both a definite trend of performance is discernible to the Board and the Boarc believes that continuation of the trend may result in a change of performance level.
The addition of Training and Qualification Effectiveness (those training programs covered by the Comission Policy Statement on Training and Qualification) as a regular functional area rather than treating it as a temporary functional area as proposed in my June 27, 1985 memorandum.
The Fire Protection and Quality Programs and Administrative Controls Affecting Quality functional areas were revised to delete the options for addressing these functional areas as a separate evaluation criterion for all appropriate functions. The option still remains not to address a functional area but provide rationale of why the area was not observed during an evaluation period.
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Multiple Addressees The enclosed revision contains "R" notations in its right hand margins to indicate where changes have been made between the November 15, 1984 revision and the enclosed revision.
We recognize that the SALP process is an evolving one and that future changes are likely. We welcome at any time comments on the SALP process and recommenda-tions for improvements.
L%,
l mes M. Taylo, Director ffice of Inspection and Enforcement
Enclosure:
NRC 0516 i
J
Multiple Addressees, memo dated November 5, 1985 Victor Stello, Jr., Deputy Executive Director for Regional Operations and Generic Requirements Office of the Executive Director for Operations fHarold R? Denton, Director'1 Office of Nuclear Reactor Regulation John G. Davis, Director Office of Nuclear Material Safety and Safeguards Clemens J. Heltemes, Jr., Director Office of Analysis and Evaluation of Operational Data Thomas E. Murley, Regional Administrator, Region I J. helson Grace, Regional Administrator, Region II James G. Keppler, Regional Administrator, Region III Robert D. Martin, Regional Administrator, Region IV John B. Martin, Regional Administrator, Region V
__--_,~
o U.S. NUCLEAR REGULATORY CO MISSION NRC MANUAL Volume: 0000 General Administration Part:
0500 Health and Safety IE CHAPTER 0516 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-01 C0VERAGE This Chapter and its appendix describe the basic structure and overall procedures for implementation of the NRC program to assess licensee per-fonnance.
This program applies to all power. reactors with operating li-censes or construction permits (hereinafter referred to as licensees).
0516-02 OBJECTIVES 021 To improve the NRC regulatory program.
022 To permit sound decisions regarding NRC resource allocations.
023 To improve licensee performance.
024 To collect available observations on a periodic basis and evalu-ate licensee performance based on those observations, through the Systematic Assessment of Licensee Performance (SALP), an inte-grated NRC staff effort.
Positive and negative attributes of licensee performance are considered.
Emphasis is placed upr understanding the reasons for a licensee's perfo h:e in impot -
tant functional areas, and sharing this understuding with t' e licensee.
The SALP process is oriented toward furthering NRC's understanding of the manner in which:
(a) licensee management directs, guides, and provides resources for assuring plant safety; and (b) such resources are used and applied.
The inte-grated SALP assessment is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to R provide meaningful guidance to licensee management.
0516-03 RESPONSIBILITIES AND AUTHORITIES 031 The Executive Director for Operations (ED0):
Provides oversight for the activities described herein.
Approved:
SYSTEMATIC ASSESSMENT OF 0516-032 LICENSEE PERFORMANCE 032 The Director, Office of Inspection and Enforcement (IE):
a.
Implements the requirements of this chapter within the Office of Inspection and Enforcement.
b.
Monitors the SALP process; evaluates and develops SALP poli-cy, criteria, and methodology; and assesses the uniformity and adequacy of the regions' implementation of the program.
033 The Directors, Offices of Nuclear Reactor Regulat' ion (NRR),
Analysis and Evaluation of Operational Data (AEOD), and Nuclear Materials Safety and Safeguards (NMSS):
Imple:nent the require-ments of this chapter within their Offices.
034 Regional Administrators:
a.
Implement the requirements of this chapter within the re-gions.
b.
Ensure that assessments of licensee nuclear safety perfor-mance are conducted.
c.
Determine when a meeting with the licensee is necessary to assure mutual understanding of the issues discussed in the -
SALP Board report.
d.
Evaluate the SALP Board report and the licensee's comments; provide a characterization of overall safety performance; formally issue the NRC SALP report; follow up on licensee commitments; and reallocate region inspection resources as appropriate.
e.
Provide to the Director, Office of Inspection and Enforce-ment, recommendations for improvements to the SALP program and comments on proposed changes to SALP policy.
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.
Not all functional areas need be covered in a given R 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.
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 functional area will be a composite of the attri-butes tempered with judgment as to the significance of individual items.
Departures from this guidance may sometimes be warranted.
Approved:
o SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
' 0516-041 In such cases, the rationale for such departures should be ex-plained 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 R auxiliary controls; plant-wide housekeeping; and con-R trol room professionalism.
R 2.
Radiological Controls Includes the following areas of activity which may be R evaluated as separate subareas to arrive at a consensus - R rating for this functional area.
R (a) Occupational Radiation Safety - includes controls R by licensees and contractors for occupational R
radiation protection, radioactive materials and R contamination controls, radiological surveys and R monitoring, and ALARA prograus.
R (b) Radioactive Waste Management - includes processing R and on-site storage of gaseous, liquid and solid R wastes.
R (c) Radiological Effluent Control and Monitoring - in-R cludes gaseous and liquid effluent controls and R monitoring, offsite dose calculations and dose R limits, radiological environmental monitoring, and R the results of NRC's confirmatory measurements R program.
R (d) Transportation of Radioactive Materials - includes R procurement and selection of packages, preparation R for shipment, selection and control of shippers R delivery to carriers, receipt / acceptance of ship-R ments by receiving facility, periodic maintenance R of packagings and, for shipment of spent fuel, R point of origin safeguards activities.
R (e) LWR Water Chemistry Controls - includes primary R and secondary systems affecting plant water chem-R Approved:
SYSTEMATIC ASSESSMENT OF 0516-042a2(e)
LICENSEE PERFORMANCE i s try, water chemistry control program and pro-R gram implementation, chemistry facilities, equip-R ment and procedures, and cheniical analysis quality R assurance.
R 3.
Maintenance Includes all licensee and contractor activities associ-R ated with preventive or corrective maintenance of in-strumentation and control equipment and mechanical and electrical systems.
4.
Su rveillance 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 (combustibles, etc.) and R fire protection / prevention program activities.
- Thus, it includes the storage of combustible material; fire brigade staffing and training; fire suppression system maintenance and operation; and those fire protection features provided for structures, systems, and conipon-ents important to safe shutdown.
6.
Emergency Preparedness Includes activities relating to the implementation of the emergency plan and implementing procedures.
- Thus, it includes such activities as licensee's performance during exercises which test the licensee, state, and local emergency plans; plan administration and imple-mentation; notification; communications; facilities and equipment; staffing; training; assessment; emergency classification; medical treatment; radiological expo-sure control; recovery; protective actions; and inter-faces with onsite and offsite emergency response organ-izations.
7.
Security Includes all activities whose purpose is to ensure the security of the plant.
Specifically it includes R all aspects of the licensee's security program (e.g.
access control, security checks, safeguards).
R Approved:
i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 5'016-042a8
)
8.
Outages R
Includes all licensee and contractor activities associ-R ated with major outages. Thus, it includes refueling, R outage management, major plant modifications, repairs R or restoration to major components (e.g., steam gener-R ator tube repairs or primary loop piping replacement), R and all post-outage startup testing of systems prior to R return to service.
R 9.
Quality Programs and Administrative Controls Affecting Quality Includes all management control, verification and over-R sight activities which affect or assure the quality of plant activities, structures, systems, and components.
This area may be viewed as a comprehensive management system for controlling the quality of work performed as well as the quality of verification activities that confinn that the work was performed correctly.
The evaluation of the effectiveness of the quality assur-ance system should be based on the results of manage-ment actions to ensure that necessary people, proced-ures, facilities, and materials are provided and used -
during the operation of the nuclear power plant.
Principal emphasis should be given to evaluating the effectiveness and involvement of management in estab-lishing and assuring the effective implementation of the quality assurance program along with evaluating the history of licensee performance in the key areas of:
committee activities, design and procurement control, control of design 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 initia-tives, and the licensee's approach to resolution of technical issues from a safety standpoint.
- 11. Training and Qualification Effectiveness R
Although this functional area is limited to the follow-R ing categories of facility training / retraining so as to R parallel those training programs covered by the Commis-R sion Policy Statement on Training and Qualification, R this functional area includes all activities relating R to the effectiveness of the training / retraining and R qualifications program conducted by the licensee's R staff and contractors for these categories of facility R training.
R Approved:
SYSTEMATIC ASSESSMENT OF 0516-042all LICENSEE PERFORMANCE Other categories of facility training / retraining should R be treated as evaluation criteria for the other func-R tional areas.
R (a) Non-licensed operators R
(b) Control room operators R
(c) Senior control room operators / shift supervisors R
(d) Shift technical advisors R
(e)
Instrument and control technicians R
(f) Electrical maintenance personnel R
(g) Mechanical maintenance personnel R
(h) Radiological protection technicians R
(i) Chemistry technicians R
(j) Onsite technical staff and managers R
- 12. Others (As Needed) b.
Construction Phase Reactors 1.
Soils and Foundations 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 prepa ration, fill materials and compaction, embankments, foundations and associated laboratory testing, and 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 sa fety-rela ted structures (welded and bolted), and najor steel equipment supports (for reactor vessel, Approved.
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-042b2 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 sy' stems.
It includes those quality checks necessary to ensure com-pliance with the applicable codes and other require-ments specified in the SAR for these systems. The pri-mary inspection emphasis in this area is on piping systems and their supportc/ restraints.
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 pip-ing.
5.
Auxiliary Systems Includes those safety-related auxiliary systems in-cluded 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 Equipment 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, switchgear, electric raceways, cable (power, control, 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.
The Reactor Protection System and the Engineered Safety Features Actuation System are two plant systems utfifz-Approved:
SYSTEMATIC ASSESSMENT OF 0516-042b7 LICENSEE PERFORMANCE ing such devices as:
sensors, transmitters, signal conditioners, controllers and other actuating devices, recorders, alarms, logic devices, instrument air sup-plies, racks, and panels.
8.
Quality Programs and Administrative Controls Affecting Quality Includes all management control, verification and over-R sight activities which affect or assure the quality of plant structures, systems, and components.
This area may be viewed as a comprehensive management system for controll.ing the quality of work performed as well as the quality of verification activities that confirm that 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, and materials are provided and used during the design and construction of the nuclear power plant. Principal emphasis should be given to evaluating the effective-ness and involvement of management in establishing and R assuring the effective implementation of the quality R assurance program along with evaluating the history of R licensee / contractor performance in the key areas of:
R quality assurance program, design and procurement con-R trol, control of construction processes, inspections, R audits, corrective action systems, and records.
R 9.
Licensing Activities R
Includes all activities supporting the NRC review of R the application for and the issuance of the Construc-R tion Permit and Operating License, and amendments R thereto.
In addition, it includes the adequacy and R timeliness of all licensing submittals, responsiveness R to NRC licensing initiatives, and the applicant's or R licensee's approach to resolution of technical issues R from a safety standpoint.
R
- 10. Others (As needed) c.
Preoperational Phase Reactors 1.
Preoperational Testing 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 re-quirements of components, systems, and structures.
1 Approved:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-042c2 2.
Others (As Needed)
For reactors in the preoperational phase, functional areas from the listing for either operating phase reac-tors or construction phase reactors should be selected as appropriate.
d.
Startup Phase Reactors 1.
Startup Testing Covers the preparation, conduct, and evaluation of test results for testing conducted following the issuance of the operating license.
It starts with initial fuel loading and precritical tests, and continues until the plant reaches commercial operating status at or-near its licensed power rating.
2.
Others (As Needed)
For reactors in the startup phase, functional areas from the listing for operating phase reactors should be used.
043 Performance Categories.
A rating of licensee performance in a given functional area.
a.
Category I Reduced NRC attention may be appropriate.
Licensee manage-ment attention and involvement are aggressive and oriented toward nuclear sa fety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety and construction quality is R 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 perform-ance with respect to operational safety and construction quality is being achieved.
R c.
Category 3 Both NRC and licensee attention should be increased. Licen-see management attention or involvement is acceptable and Approved:
=.
SYSTEMATIC ASSESSMENT OF 0516-043c LICENSEE PERFORMANCE l
l 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 and construction quality is being R achieved.
044 Trend. The SALP Board may determine to include an appraisal of R the performance trend of a functional area. Normally, this per-R formance trend should only be used where both a definite trend of R performance is discernible to the Board and the Board believes R that continuation of the trend may result in a change of perfor-R mance level.
The Board's appraisal of the performance trend, if R used, should appear as a Board Coment.
It should be used selec-R tively and should be reserved for those instances where the Board R believes that it is necessary to focus NRC and licensee attention R on an area because of a declining performance trena, or to credit R licensee performance because of an improving trend.
R The trend, if used, is defined as:
R a.
Improving R
Licensee performance was determined to be improving near the R close of the assessment period.
P l
b.
Declining R
Licensee performance was determined to be declining near the R close of the assessment period.
R 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.
Mtagement involvement in assuring quality 2.
Approach to the resolution of technical issues from a safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Operational and Construction events (including response R'
to, analysis of, and corrective actions for)
R 6.
Staffing (including management)
Approved:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0$16-045b b.
Guidance for using these criteria to arrive at a category assignment is found in the Appendix to this Chapter.
0516-05 BASIC REQUIREMENTS 051 A )plicability.
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.
END i
1 o
i Approved:
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC AP'PENDIX 0516 O
APPENDIX l
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 1
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
. _ _ _, -. _ _., _,,.. _. _., - -,. ~ _,, - -
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 CONTENTS P.BA*
PART I GENERAL.....................
1 PART II EVALUATION CRITERIA...............
4 PART III SALP BOARD ASSESSMENT..............
9 PART IV MEETING WITH LICENSEE..............
13 PART V ISSUANCE OF REPORT 15 PART VI APPENDIX TO THE SALP REPORT...........
16 PART VII -
SALP REPORT FORMAT AND CONTENT 17 FIGURES FIGURE 1 SALP EVALUATION PROCESS.............
3 TABLES P, age TABLE 1 Evaluation Criteria With Attributes for Assessment of Licensee Performance 5
TABLE 2 Evaluation Matrix for Operating Phase Functional Areas 11 TABLE 3 Evaluation Matrix for Construction Phase Functional Areas 12 EXHIBITS EXHIBIT 1 -
Samples of Overall Safety Performance Characterizations.......
18 EXHIBIT 2 -
SALP Board Report.
19 EXHIBIT 3 -
An Errata Sheet.
27 EXHIBIT 4 -
Original Page.
28 EXHIBIT 5 -
Corrected Page 29 i
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART I PART I GENERAL A.
The SALP program was established to improve the NRC Regulatory Pro-gram, 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.
When the Regional Administrator determines that a particular utility or facility should be evaluated more frequently. Licen-R sees which were assigned category Three performance in several R functional areas during the previous evaluation period should be R considered for evaluation on a annual basis; R
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 months before the scheduled R licensing date; or 3.
When a new operating license is issued, two SALP evaluations R should be scheduled at approximately 12 months intervals. The R first of these two evaluations should be scheduled for completion R approximately 12 months after the SALP evaluation conducted R during the preoperational phase just prior to issuance of the R operating license. The second of these two evaluations should be R completed approximately 12 months later.
Following completicr. R of these two evalualtions, it is expected that most facilities R would then be placed on a normal schedule.
R 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; 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. A licensee managment meet-R ing should be considered by the Regional Administrator in those R l
l 1
c.
.n.
- -.,., - - - - - - - ~.
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 cases where it appears that licensee performance is such that an R order imposing a Regulatory Improvement Program or other sanc-R l
tions may be appropriate; R
4.
Consideration of any written response received (or required) from R the licensee and issuance of an appendix to the SALP report which R is to include the verbatim written response received from the R licensee and the conclusions of the Regional Administrator on the R basis of his consideration of the response.
R D.
Procedures for implementing the SALP program are provided in this R Appendix.
R 2
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART II FIGURE 1 SALP Evaluation Process SALP Board Preparation (Part III)
SALP Board Meeting (Part III)
SALP Report Issuance (Part V) 9 Meeting with the Yes Licensee?
~
No Meeting with the Licensee (Part IV)
Licensee Responds Appendix to the SALP Report (Part VI) 3 1
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 six evaluation criteria.
The criteria provide standard guidance that R 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 six criteria discussed in Chapter NRC-0516-045 are listed in Table 1 R 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 attributes influence established programs of the agency. For example, it is not intended that specific inspectiors 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.
However, matters such as management involvement and staffing are criteria R of each functional area and should be considered in the evaluation of the R functional areas.
R It is emphasized that all available information should be analyzed by the SALP Board, and its significance, whether it be positive o-
- negative, should be weighed.
If information is scarce or nonexistent, a decision regarding the performance category as it relates to an attribute should not R be forced.
4
l TABLE 1 EVALUATION CRITERIA WITH ATTRIBUTES FOR ASSESSMENT OF LICENSEE PERFORMANCE 1
{
Category 1 Category 2 Category 3
)
1 j
l 1.
Management Involvement in Assuring Quality consistent evidence of prior evidence of prior planning and little evidence of prior planning and assignment of assignment of priorities; planning and assignment of priorities; well stated, stated, defined procedures for priorities; poorly stated or controlled and explicit control of activities ill understood procedures for control of activities procedures for control of activities p
i l
well stated, disseminated, adequately stated and understood poorly stated, poorly under-and understandable policies policies stood or nonexistent policies i
decisionmaking consistently decisionmaking usually at a level decisionmaking seldom at a at a level that ensures that ensures adequate management level that ensures adequate adequate management review review management review i
corporate management frequently corporate management usually in-corporate management seldom l
involved in site activities volved in site activities involved in site activities i
l reviews timely, thorough, and reviews generally timely, reviews not timely, thorough technically sound thorough, and technically sound or technically sound records complete, well, records generally complete, records not complete, not well i
maintained, and available well maintained, and available maintained, or unavailable i
i procedures and policies procedures and policies rarely procedures and policies l
strictly adhered to violated occasionally violated l
corrective action is effective, corrective action is usually corrective action is not timely R
]
as indicated by lack of repetition taken but may not be effective or effective and generally ad-R at correcting the root cause of dresses symptoms rather than R
l of the problem, as indicated by root causes, events are repeti-R occasional repetition tive R
i i
i
}
i
Category 1 Category 2 Category 3 1
2.
Approach to the Resolution of Technical Issues from a Safety Standpoint clear understanding of issues understanding of issues understanding of issues demonstrated generally apparent frequently lacking conservatism routinely conservatism generally meets minimum requirements exhibited when potential for exhibited j
safety significance exists technically sound and thorough viable and generally sound and often viable approaches; but approaches in almost all cases thorough approaches lacking in thoroughness or depth timely resolutions in almost generally timely resolutions resolutions often delayed i
all cases i
f 3.
Responsiveness to NRC Initiatives I
reets deadlines generally timely responses frequently requires extensions of time timely resolution of issues few longstanding regulatory longstanding regulatory issues issues attributable to licensee attributable to licensee l
j technically sound and thorough viable and generally sound and often viable responses, but responses in almost all cases thorough responses lacking in thoroughness or depth k
acceptable resolutions proposed acceptable resolutions considerable NRC effort or
{
initially in most cases generally proposed repeated submittals needed to obtain acceptable resolutions 4
l 4.
Enforcement History major violations are rare and major violations are rare and multiple major violations or are not indicative of may indicate minor programmatic programmatic breakdown indicated programmatic breakdown breakdown l
t
Category 1 Category 2 Category 3 4.
Enforcement History (Continued) 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 corrective action is prompt and corrective action is timely and corrective action is delayed or effective effective in most cases not effective 7
5.
Operational and Construction Events a
few significant operational or con-occasional significant operational frequent significant operational R
struction events, attributable to or construction events, attributable or construction events, attrib-R 4
causes under the licensee's control, to causes under the licensee's con-utable to causes under the licen-R have occurred that are relevant to trol, have occurred that are relevant see's control, have occurred that R this functional area to this functional area are relevant to this functional R
area events are promptly and completely events are reported in a timely event reporting is frequently R
I reported manner, some information may be late or incomplete R
lacking R
events are properly identified and events are accurately identified, events are poorly identified or R analyzed some analyses are marginal analyses are marginal, events are R associated with programmatic weak-R nesses R
6.
Staffing (Including Management) i positions are identified, authorities key positions are identified, and positions are poorly identified, and responsibilities are well defined responsibilities are defined or authorities and responsibilities j
are ill defined vacant key positions are filled on key positions usually filled in a key positions are left vacant for j
a priority basis reasonable time extended periods of time i
4
L i
Category 1 Category 2 Category 3 6.
Staffing (Including Managenent)
(Continued) staffing is ample as indicated by con-staffing is adequate, occasional dif-staffing is weak or minimal as in-trol over backlog and overtime ficulties with backlog or overtime dicated by excessive backlog and overtime experience levels for management and experience levels for management and experience levels for managment and operations personnel exceed commit-operations personnel meet commitments operations personnel are below com-ments made by licensee at time of made by licensee at time of licensing mitments made by licensee at time licensing of licensing
(
7.
Training and Qualification Effectiveness l
training and qualification program training and qualification program training and qualification program I
makes a positive contribution, com-contributes to an adequate under-is found to be the major contribu-mensurate with procedures and staff-standing of work and fair adherence ting factor to poor understanding ing, to understanding of work and to procedure with a modest number of work, as indicated by numerous adherence to procedures with few of personnel errors procedure violations or personnel errors personnel errors I
training program is well defined a defined program is implemented program may be either lacking, I
and implemented with dedicated for a large portion of the staff poorly defined, or ineffectively resources and a means for feedback applied for a significant segment of the staff experience; program is applied to j
nearly all staff inadequate training could rarely be inadequate training could occasionally inadequate training could regularly traced as a root cause of major or be traced as a root cause of major or be traced as a root cause of major minor events or problems occurring minor events or problems occurring or minor events or problems occurring I
during the rating period during the rating period during the rating period i
l l
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART III PART III SALP BOARD ASSESSMENT A.
SALP Board Preparation Each region snall:
R 1.
Issue a memorandum establishing the assessment period, SALP Board R input due date, SALP Board meeting date, and expected date of licensee meeting, if necessary, for all facilities within the R region for all SALP meetings scheduled to occur in the calendar R year. This memorandum shall be sent to NRR, IE, NMSS, AE00, and R the EDO by the end of the preceding calendar year.
Changes to R SALP schedules should also be provided to these Offices. SALP R Board members shall be notified promptly of unavoidable schedule R problems to facilitate coordination of setting alternate meeting R dates.
R 2.
Prepare a draft of the SALP Board Report.
R a.
Obtain SALP Board inputs. NRR shall provide a written input R to the Licensing Activities area. Other program offices R should provide any known significant information based upon R headquarters activities.
R 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 for fo rma t. )
d.
Issue a draft of the SALP Board Report to meeting pa rtici-R pants in advance of the SALP Board Meeting date.
R B.
SALP Board Meeting 1.
The SALP Board meeting should be conducted within 45 days of the R end of the assessment period. This meeting will be conducted R under a regionally generated SALP Board procedure.
R 2.
The SALP Board shall be composed of the following voting members:
R l
a.
SALP Board Chairman (Division level manager or above) b.
NRR Project Manager
.g.
NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART III LICENSEE PERFORMANCE c.
NRR management representative d.
Senior Resident Inspector e.
Representatives from IE, AE00, and NMSS when determined R appropriate by the respective Office Director R
f.
Other individuals as determined by the Regional Administrator g.
Regional Administrators are encouraged to arrange for the R occasional participation of Division level managers from R other regions on SALP Boards.
R 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. Ratings shall be R determined by majority vote of the Board's voting members.
R c.
Recommend changes to the inspection program emphasis, as necessa ry. - _ _
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D SYSTEMATIC ASSESSMENT OF NRC APP.ENDIX 0516 LICENSEE PERFORMANCE PART IV PART IV MEETING 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 to the licensee, the cognizant regional personnel, the.R resident inspectors at the involved facilities, the NRR Project R Managers for the involved facilities, and cognizant NRC 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.
Meeting with Licensee 1.
The meeting (if held) should be conducted within 90 days of the end of the assessment period.
2.
NRC representatives for this meeting should include the following:
Either the Regional Administrator, Deputy Administrator, or a.
a Division Director b.
Responsible Regional Division Director (s), Branch Chiefs, or Section Chiefs, as appropriate c.
NRR Project Manager and designated NRR manager d.
Resident Inspector and/or assigned inspectors 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 candid discussion of issues relating to the licensee's performance.
Those aspects of the licensee's operation that need improvement will be identified. _ _
' NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART IV LICENSEE PERFORMANCE The good aspects of the licensee's performance shculd also be R identified.
R 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 meet-ings that involve discussion of matters not required to be manda-torily placed in the public domain pursuant to 10 CFR 2.790, 1
which must be closed. Members of the public should be treated as observers.
Adequate notification of the SALP meeting can be ac-complished by PDR distribution of the letter to the licensee which schedules the meeting, with copies to the service list for the appropriate docket.
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SYSTEMATIC ASSESSMENT OF NRC 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 issued to the R licensee under signature of the Regional Administrator with copies to R Director, IE; Director, NRR; the Comissioners and the IE SALP Coordi-R nator. The transmittal letter should include:
R 1.
A request for the licensee's written comments and amplification, R as appropriate, on the SALP report within 30 days after the li-R censee meeting (if held) or receipt of the SALP Board report. R For all functional areas rated as Category Three, the transmittal R
letter shall require a licensee response providing planned cor-R rective actions to achieve improved performance; R
2.
Amplification of the findings of the SALP Board as appropriate. R 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 characterization of overall safety performance.
R This letter, enclosing the SALP Report, will receive standard docket distribution including the NRC Public Document Room and the local Public Document Room, and INP0 (Record Center, INP0; 1100 Circle 75 Parkway; Suite 1500; Atlanta, GA 30339).
Each report will be assigned an Inspection Report number.
B.
Changing 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.
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE
' PART VI PART VI APPENDIX TO THE SALP REPORT A.
General The Regional Administrator shall issue an appendix to the SALP report R within 30 days of receipt of the licensee's written comments or R planned corrective actions. This appendix will receive standard dock-R et distribution including the NRC Public Document Room, the local R
Public Document Room and INP0.
R B.
Appendix to the SALP Report The appendix to the SALP report shall consist of:
1.
The verbatim written comments received from the licensee; 2.
A summary of any meetings held with the licensee concerning the SALP report; 3.
Comments on the acceptability of licensee's planned c';rrective R actions, if required; and R
4.
The conclusions of the Regional Administrator on the basis of his R consideration of the licensee's comments or planned corrective R actions.
R 1 l
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART VII PART VII i
SALP REPORT FORMAT AND CONTENT A.
General l
The SALP Board report is considered to be a final report upon approval by the Board, signature of the transmittal letter by the Regional
^
Administrator, and dispatch to the licensee.
B.
Multiple Facility Licensees i
In cases such as Duke, TVA, and Commonwealth Edison, the SALP package R l
may address more than one site. However, each site should have a sep-arate SALP Board 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
)
- lL-
NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE EXHIBIT 1 Samples of Overall Safety Performance Chacterizations Example 1 Overall, we find that your performance of licensed activities generally is acceptable and directed toward safe facility operation.
In addition, your overall performance has shown only moderate improvement since the last SALP evaluation period.
Your performance in the area of Plant Modifica-tions 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 evident that safe operation and compliance with regulatory requirements are 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 Controls and the long standing problems associated with the existing perimeter alann system.
Example 3 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 strength was noted in the area of refueling.
Example 4 Overall, we found your performance acceptable and directed toward safe facility operation.
In addition, we found your overall performance im-t proved since the last SALP evaluation period.
We found aggressive 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 are adequately controlled was found to need increased attention on your part and we will pay particular attention to this area during our subsequent inspections..__ __ -.
NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE EXHIBIT 2 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION REGION [ region]
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
[ Inspection Report Nun,ber]
[Name of Licensee]
[Name of Facility]
4
[ Assessment Period]
t 1
i.
NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE EXHIBIT 2 (Cont'd)
I.
INTRODUCTION The Systematic Assessment of Licensee Performance (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 information.
The SALP program is supplemental to normal regulatory processes used to ensure compliance with. NRC rules and regulaticns. The SALP program is intended to be sufficiently diagnos-tic 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, j
An NRC SALP Board, composed of the staff members listed below, met on j
[date], to review the collection of performance observations and data, and to assess licensee performance in accordance with the guidance in i
NRC Manual Chapter 0516, " Systematic Assessment of Licensee Perform-l ance."
A summary 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 j
performance at [name of facility] for the period [date] through [date]..
j SALP Board for [name of facility]:
[ List SALP Board Members]
l 4
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i a
f 1
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I - - _ - ~ _. _ -. _ _., _ _
_ _ _ _. _ _,.. - ~ _,, _ _ _.
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0156 LICENSEE PERFORMANCE PART VII EXHIBIT 2 (Cont'd)
II.
CRITERIA Licensee performance is assessed in selected functional areas, depend-ing upon whether the facility is in a construction, preoperational, or operating phase.
Functional areas normally represent areas signifi-cant to nuclear safety and the environment.
Some functional areas may R 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 the resolution of technical issues from a safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Operational and Construction events (including response to, R
analyses of, and corrective actions for)
R 6.
Staffing (including management)
R 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 definitions of these performance categories are:
Category 1.
Reduced NRC attention may be appropriate.
,icensee management attention and involvement are aggressive and,riented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respr.ct to operational safety and construction quality is being achieved.
R Category 2.
NRC attention should be maintsined at normal levels.
Licensee management attention and involveaent 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 and construction quality is being achieved.
R 1 3
._ ~ -. _ _ -_ -
NRC APPENDIX 1516 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE P$RFORMANCE EXHIBIT 2 (Cont'd)
Category 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 and construc-tion quality is being achieved.
R III.
SUMMARY
OF RESULTS
[ Provide a narrative summary of the licensee's overall significant strengths and weaknesses.
It should be similar to the overall performance narrative used in the letter to the licensee.]
I i.
Functional Area
[last period]
[this period]
R
[ functional area]
[ rating last
[ rating this R
period]
period]
1 IV, PERFORMANCE 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 per-formance.
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 analysis should concentrate on the adequacy of the li-censee'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 con-clusions reached with the attributes of each category.
The attributes listed in Part II are specifically oriented toward this and should be utilized.
In no event, however, - _ - _. _.. _ _ _
F o
SYSTFMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART VII EXHIBIT 2 (Cont'd) are the examples of licensee performance for specific attri-butes 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:
A brief account of the inspection activity which oc-curred in this area.
A brief summary of the previous evaluation if there has R 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 the evaluation period.
2.
Conclusion
[ Provide the performance assessment (Category 1, 2, or 3) R for each functional area considered.]
R 3.
Board Recommendations
[ Include any general or specific Board recommendations per-R taining to either licensee management attention or NRC in-R spection activities in a functional area.
If appropriate, R include a trend assessment (improving or declining), charac-R ter1 zing licensee performance near the close of the assess-R ment period. Note that even in the absence of a recommenda-tion to vary inspection levels, the regional office may do so based on the assessment as discussed in appropriate chap-ters of the IE manual.]
i i
1 !
r NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE EXHIBIT 2 (Cont'd)
V.
SUPPORTING DATA AND SUMMARIES A.
Licensee Activities
[ Provide an outline of major licensee activities, such as major outages, power limitations, important license amendments, and significant modifications.]
B.
Inspection Activities
[ Provide a summary of major inspection activities in each func-tional area.
This is not intended to be a summary of each rou-tine inspection performed, but rather a summary of major inspec-tion activities such as team inspections.
Include Table I.]
C.
Investigations and Allegations Review
[ Provide a summary of major investigative activities and their results.]
D.
Escalated Enforcement Actions 1.
Civil Penalties [ Provide a summary]
2.
Orders (only those relating to enforcement) [ Provide a summary]
E.
Licensee Conferences Held During Appraisal Period R
[ Discuss conferences that dealt with regulatory performance or R enforcement.]
R F.
Confirmation of Action Letters R
[ Provide a summary.]
R G.
[Ct.mr]
[ Discuss any other issues at the discretion of the SALP Board.]
H.
Review of Licensee Event Reports, Construction Deficiency Reports, and 10 CFR 21 Reports Submitted by the Licensee
[ Provide a brief summa ry of siclificant findings and trends resulting from a review of these reports. If this information is contained in another section of the report, this item may be omitted.]
~
~
~ ~
i SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 l
LICENSEE PERFORMANCE
'PART VII I.
Licensing Activities R
[ Provide a summary of significant occurrences in each of the R
~
following categories of NRR licensing activities.. The sum-R maries should provide a basis that demonstrates the signiff-R cance of the licensee's programs, and the importance and re-R l
sources assigned by the licensee to the programs.]
R I
1.
NRR/ Licensee Meetings [ Discuss meetings that dealt with R significant licensing issues.]
R i
2.
Commission Meetings [ Discuss meetings that dealt with R l
significant licensing issues.]
R 3.
Schedular Extensions Granted R
l 4.
Reliefs Granted R
5.
Exemptions Granted R
6.
License Amendments Issued R
7.
Orders Issued R
8.
Issues Pending R
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_ - _ - - - -. _ _ _, _., - _ _ _ _. - _.. ~ - _ _
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART VII EXHIBIT 2 (Cont'd) i TABLE 1 1
ENFORCEMENT ACTIVITY
)
FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL AREA V
IV III II I
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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 REAb 5
24 operator's cognitive decision operator's decision Basis: The word cognitive was deleted to avoid further problems in inter-preting its meaning.
As used, the work was intended to mean that the operator, as the cognizant individual on shift, knew the opera-ting requirements of the Technical Specification but r.1ade a con-scious decision to operate the plant in a manner which t.e felt was J
equivalent to the requirements. It was not intended to mean that the operator took actions in total disregard of the Technical Speci fication objectives.
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NRC APPENDIX 0516 SYSTEMATIC ASSESSMENT OF PART VII LICENSEE PERFORMANCE EXHIBIT 4 ORIGINAL PAGE
- 0) Severity Level IV - Failure to take timely and proper corrective action following the failure of a cold leg RTD (50-000/81-24).
(11) everity Level VI - failure to make a 30 day report on a degraded b s voltage relay (50-000/81-26).
Six of the oncompliances were for failure to make required reports or to make time reports, four for failure to follow procedures, and one for incomplet documentation.
One noncompliance for failure to properly report a breach in containment, Item -(9) above, is part of an escalated enforcement acti th Civil Penalty.
The actual event, is described in Section 4, Surv ance.
Nine LER's relating t this area were caused by personnel errors, six at Unit 1 and three at 2.
Sixty percent of these occurred in the last half of the perio M thirty percent in the last quarter indicat-ing an increasing occurFTn rate in the period.
Six of the nine were -
for incorrect valve or b k
lignments and three were for failure to follow operating procedu Two events (LER's 50-000/81-0-000/81-52) were of particular concern since they reflected a lic d operator's cognitivt decision to operate a system (charging and $
and containment isolation, respectively) in a manner not allo the Technical Specifications.
Unit 1 experienced nine automatic tri uring the evaluation period, four caused by operator error and five quipment failure.
Of the four caused by errors, two were due to in ctly conducted instrument surveillance tests, one to an incorrect va ineup on the steam side, and the last to unfamiliarity with turbine c t is.
Unit 2 experienced nine reactor trips, one beit a manually initiated turbine trip.
Four of the trips were related to per nnel errors; two by loss of vacuum in the main condenser, one resulted om a low steam generator level, and one resulted from a turbine valve misalignment.
No significant safety concern is associated with these tri s and each was reviewed to verify proper safety system operation an operator actions.
Various operating problems and events identified during the p iod resulted in an enforcement meeting on August 4, 1981, with folio up meeting on August 4, 1981, with followup meetings on November 2, 19 5
(
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE PART VII EXHIBIT 5 CORRECTED 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).
(11) Severity Level VI - Failure to make a 30 day report on a degraded bus voltage relay (50-000/81-26).
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 for 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 were caused by personnel errors, six at Unit 1 and three at Unit 2.
Sixty percent of these occurred in the last half of the period and thirty 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 procedures.
Two events (LER's 50-000/81-67 and 50-000/81-52) 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.
Unit 1 experienced nine automatic trips during the evaluation period, four caused by operator error and five by equipment failure.
Of the four caused 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 manually 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 mcting on August 4, 1981, with followup meeting on August 4, 1981, with followup meetings on November 2, 1981 5