ML20198E343
| ML20198E343 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Caldwell J, Miller H, Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9812240038 | |
| Download: ML20198E343 (9) | |
Text
'
- hY(Lk kC3
\ p e8 400
{
p & UNITED STATES 1 g j NUCLEAR REGULATORY COMMISSION l
WA8HINGToN, D.C. 20666 4 001
'+,*****,o December 15, 1998 MEMORANDUM TO: Hubert J. Miller, Regional Administrator, RI Luis A. Reyes, Regional Administrator, Ril James L. Caldwell, Acting Regional Administrator, Rlli Ellis W. Merschoff, Regional Administrator, RIV FROM: ector Office of Nuclear Reactor Regulation
SUBJECT:
COMMUNICATING RESULTS OF PLANT PERFORMANCE REVIEWS The staff requirements memorandum (SRM) dated September 15,1998, for COMSECY-98-024,
)
" Response to issues Raised Within the Senate Authorization Context and July 17,1998 '
Stakeholder Meeting," directed the staff to suspend the Systematic Assessment of Licensee Performance (SALP) program. This memorandum provides guidance regarding PPR letter ,
format and content, and supplements my September 24,1998, memorandum to all regional l l
administrators suspending the SALP program. Inspection Manual Chapter (IMC) 0304," Plant Performance Reviews," will be modified as appropriate following completion of the ongoing accelerated initiatives discussed in COMSECY-98-024 and its updates.
The next Plant Performance Reviews (PPRs) should be scheduled in early 1999 to align with l the annual Senior Management Meeting (SMM) process. Letters that communicate the results of the PPRs should be issued to alllicensees shortly after the SMM screening meetings to I ensure consistency in assessment infom1ation. Public meetings should be scheduled and I conducted as outlined in the September 24 memorandura to discuss the results of the PPRs.
For planning purposes, a "mid-cycle" PPR should be held approximately six months after the early 1999 PPR. The primary purpose of the mid-cycle PPR is to adjust NRC inspection resources, if appropriate, based on licensee performance. Similar to current PPR letters, the letter communicating the rest ts of this PPR should emphasize changes or trends in licensee performance since the last assessment, and the level of detail for assessment information must be sufficient to make clear the reasons for any changes in inspection effort. Public meetings scheduled after the mid-cycle PPR should also address the assessment information provided after tae early 1999 PPRs.
\\\
k i
The SRM directed that PPR letters shall include performance trend information. This means that additional assessment information must be provided beyond that previously contained in PPR letters. The PPR letter will be the primary means to communicate assessment information until a new assessment process is implemented; therefore, the level of detail must be sufficient J
[h ;
for all NRC stakeholders, including state and local officials and members of the public, to understand licensee performance. In general, the level of detail should be based on the safety CONTACT: Tom Boyce, NRR/PIPB 50 4 wS-IA g g yy t._3 c mcl 301-415-1130 ---
, pgAg pb Lomnb 9812240038 981215 "
l l
2 significance and breadth of issues, with emphasis on significant programmatic or technical issues, to ensure that management attention is focused on significant issues. For those plants that warrant increased regulatory and plant management attention, and plants that will be discussed at the SMM, the letter should provide a corresponding level of detail of discussion.
For planning purposes, the new assessment process is also anticipated to communicate the information used to assess licensee performance.
Attachment 1 provides a sample PPR cover letter to be sent to licensees following the early 1999 PPPs. The letter is based on using existing information in the narratives currently developed for PPR and SMM screening meetings. In general, PPR letters must examine long term trends, particularly since the last SMM, with emphasis on performance trends during the most recent six months. Performance overviews should be provided as well as performance in each functional area, and the discussion should be supported by issues that are documented in the attached Plant Issues Matrix (PIM). Significant issues should be included in the discussion if appropriate to clearly illustrate performance assessment. The discussion should include any known significant actions taken by the licensee to address performance issues, such as licensee self-assessments and corrective actions, provided this information is docketed and publically available. Attachment 2 provides an example of a completed PPR letter.
Regional Division of Reactor Projects (DRP) branch chiefs may continue to sign PPR letters.
However, the appropriate division director should sign PPR letters for plants where licensee performance trends warrant increased management attention. A copy of all PPR letters should be sent to the Chief, inspection Program Branch, NRR and the Chief, Regional Operations and Program Management Section, OEDO. The attached PIMs should contain data since the last SALP report, but need not contain data earlier than October 1,1997. Future PIMs attached to PPR letters should contain data since the period covered by the last SALP report or PPR letter that was discussed at a public meeting, or 24 months, whichever is longer.
Attachments: As stated cc: W. Hehl, RI D. Chawaga, RI L. Plisco, Rll R. Lanksbury, Rlli G. Grant, Rlli L. Yandell, RIV T. Gwynn, RIV M. Tschiltz, EDO J. Lieberman, OE G. Tracy, EDO V. Dricks, OPA OSP W. Beecher, OPA F. Miraglia, EDO Distribution:
Central Files PIPB R/F PDR DOCUMENT NAME: G:\SECY2\PPR-LTR.WPD
- Ss3 previous concurrence.
p b To rec ive a copy of this document. indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE PlPB: DISP E DISP:Npjf PIPB: DISP E PIPB: DISP E E IQ: W E NAME THBoyce
- MRJohnson
- CFHolden
- FPGill4(#e , Sh!! ins /
DATE 12/07/98 12/08/98 12/10/98 12/15 /9$U 12/15 /98 OFFICIAL RECORD COPY
~
i .'
l l 2 period since the last assessment (e.g., SALP reports), with emphasis on performance trends during the most recent six months. Performance overviews should be provided as well as i
performance in each functional area, and the discussion should be supported by issues t are l
documented in the attached Plant issues Matrix (PIM). The discussion should include y known significant actions taken by the licensee to address performance issues, suc s licensee self-assessments and corrective actions.
I Regional Division of Reactor Projects (DRP) branch chiefs may continue topign PPR letters.
However, the appropriate division director should sign PPR letters for plants where licensee l
performance trends warrant increased management attention. A copyplall PPR letters should be sent to the Chief, Inspection Program Branch, NRR and the ChiefjRegional Operations and Program Management Section, OEDO. The attached PIMs shoupl 'contain data since the last SALP report, but need not contain data earlier than October 1,1997. Future PIMs attached to PPR letters should contain data since the period covered by t ellast SALP report or PPR letter that was discussed at a public meeting.
Attachments: As stated cc: W. Hehl, RI D. C waga,RI L. Plisco, Rll R. nksbury, Rlll G. Grant, Rill L. andell, RIV T. Gwynn, RIV . Tschiltz, EDO J. Lieberman, OE G. Tracy, EDO V. Dricks, OPA OSP W. Beecher, OPA Distribution:
Central Files PlPB R/F DOCUMENT NAME: G:\SECY2\PPR-LTR.WPD
- See previous concurr ce.
l To r t.eive a copy of this docutnent. Indicate in the box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy 5' OFFICE
~
PIPB: DISP E PIPB: DISP E IPIPB: DISP & 6 DISP:NRR D:NRR l NAME THBoyc'e TYj MRJohnsothA CFHolden ds/, ,o FPGillespie SJCollins DATE 12/ 7 /98 12/ $ /98 4# 12/ 10 /98" Fi 12/ /98 12/ /98
/ OFFICIAL RECORD COPY
/
/
l l
d b
2 significance and breadth of issues, witn emphasis on significant programmatic or technical issues, to ensure thLt management atter' tion is focused on significant issues. For those plants j that warrant increased regulatory and plant management attention, and plants that will be discussed at the SMM, the letter should provide a corresponding level of detail of discussion. !
For planning purposes, the new essessment process is also anticipated to communicate the information used to assess licensee performance.
,' Attachment 1 provides a sample PPR cover letter to be sent to licensees following the early 1999 PPRs. The lettet is based on using existing information in the narratives currently developed for PPR and SMM screening meetings. In general, PPR letters must examine long l f term trends, particularly since the last SMM, with emphasis on performance trends during the
! most recent six months. Performance overviews should be provided as well as performance in
- each functional area, and the discussion shculd be supported by issues that are documented in i the attached Plant issues Matrix (PIM). Significant issues should be included in the discussion if appropriate to clearly illustrate performance assessment. The discussion should include any '
j known significant actions taken by the licensee to address performance issues, such as licensee 4
self-assessments and corrective actions, provided this information is docketed and publically i
available. Attachment 2 provides an example of a completed PPR letter.
Regional Division of Reactor Projects (DRP) branch chiefs may continue to sign PPR letters.
However, the appropriate division director should sign PPR letters for plants where licensee performance trends warrant increased management attention. A copy of all PPR letters should l be sent to the Chief, inspection Program Branch. NRR and the Chief, Regional Operations and i Program Management Section, OEDO. The attached PIMs should contain data since the last i SALP report, but need not contain data earlier than October 1.1997. Future PIMs attached to 1 PPR letters should contain data since the period covered by the last SALP report or PPR Ic%r I that was discussed at a public meeting, or 24 months, whichever is longer.
Attachments: As stated cc: W. Hehl, RI D. Chawaga, RI L. Pli?co, Ril R. Lanksbury, Rlli G. Grant, Rlli L. Yandell, RIV T. Gwynn, RIV M. Tschiltz, EDO J. Lieberman, OE G. Tracy, EDO V. Dricks, OPA OSP W. Beecher, OPA F. Miraglia, EDO
i . .
I PPR SAMPLE LETTER ,
l l
) Licensee distribution designate Licensee name/ address
SUBJECT:
PLANT PERFORMANCE REVIEW- SITE NAME I l On (date), the NRC staff completed a Plant Perforinance Review (PPR) of (plant name). The j staff conducts these reviews for all operating nuclear power plants to develop an integrated
- understanding of safety performance. The results are used by NRC management to facilitate
- planning and allocation of inspection resources. PPRs provides NRC management with a 1 current summary of licensee performance and serve as inputs to the NRC's senior management 1 meeting (SMM) reviews. The PPR for (plant name) involved the participation of all technical i' divisions in evaluating inspection results and safety performance information for the period i (include months and years). As discussed in the NRC's Administrative Letter 98-07 of l j October 2,1998, the PPR provides an assessment oflicensee performance during an interim !
j period that the NRC has suspended its Systematic Assessment of Licensee Performance j (SALP) program. The NRC suspended its SALP program to complete a review of its processes l for assesslag performance at nuclear power plants. At the end of the review period, the NRC !
l will decide whether to resume the SALP program or terminate it in favor of another process. )
l The NRC's most recent summary of licensee performance was provided in a let'.er of (include i date of SALP letter) and was discussed in a public meeting with you on (include date of
!l i
meeting).
l 1 During this period, (provide a brief summary of plant operating history).
I
{ Overall, performance at (plant name) was (improved /decilned/ consistent). (Mclude a plant i performance overview, similar to the first paragraph (s) in Section I of current PPR and
! SMM screening meetings narratives. Discussion of SMM template areas is not required or desired in this letter.)
l Performance in (include functional area) was (improved / declined / consistent). _ (For each i functional area, include 1-2 paragraphs on performance trends.- Each functional area j should be concluded by a statement of any changes to the inspection effort or whether i core inspection effort would be maintained. This discussion should be similar to J paragraphs' il.A and II.C of current SMM narratives, and should include appropriate i references to examples in the PlM. Consider licensee problem identification and
! corrective actions, if appropriate and the information is docketed and publically i
available. . Use plain Engilsh to the extent possible and avoid overly technica19rgon.)
l Ents. ire 1 contens a historical listing of plant issues, referred to as the Plant issues Matrix
- (PlM), that were considered during this PPR process to arrive at an integrated view of licensee l performance trends. The PIM includes items summarized from inspection reports or other i docketed correspondence between the NRC and (licensee name). The NRC does not attempt j to document all aspects of licensee progrsms and performance that may be functioning appropriately. Rather, the NRC only documents issues that the NRC believes warrant i management attention or represent noteworthy aspects of performance. In addition, the PPR j may also have considered some predecisional and draft material that does not appear in the J
i j Attachment 1 I'
2 attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
l This material will be placed in the PDR as part of the normal issuance of NRC ir.spection reports I and other correspondence.
This letter advises you of our planned inspection effort resulting from the (plant name) PPR I review. It is provided to minimize the resource impact on your staff and to allow for scheduling l
conflicts and personnel availability to be resolved in advance of inspector arrival onsite.
Enclosure 2 details our inspection plan for the next 6 months. (include additional months as necessary to ensure that the inspection schedule covers the period until the next PPR letter). Also included in the plan are NRC non-inspection activities. (include this sentence only when non-inspection activities are provided in the inspection / activity plan). The l
rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed due to their ongoing and continuous nature.
We willinform you of any changes to the inspection plan. If you have any questions, please contact (DRP Branch Chief) at (telephone number).
(Signed by), Chief Reactor Projects Branch Division of Reactor Projects Docket Nos. 50-ABC, 50-XYZ License Nos. NPF-0, NPF-00
Enclosures:
- 1. Plant Issues Matrix
- 2. Inspection Plan cc:
Normal cc list + any additional SALP recipients Distribution:
Normal distribution list
+ Chief, NRR/ DISP /PIPB l
+ Chief, OEDO/ROPMS
+ TBoyce, NRR/ DISP /PlPB l
t 1
. 1 l
PPR EXAMPLE LETTER l Licensee distribution designate Licensee name/ address
SUBJECT:
PLANT PERFORMANCE REVIEW-(PLANT NAME) UNITS 1 AND 2 l
On (date), the NRC staff completed a Plant Performance Review (PPR) of (plant name). The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance. The results are used by NRC management to facilitate planning and allocation of inspection resources. PPRs provides NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews. The PPR for (plant name) involved the participation of all technical i
divisions in evaluating inspection results and safety performance information for the period November 5,1996 to August 1,1998. As discussed in the NRC's Administrative Letter 98-07 of October 2,1998, the PPR provides an assessment of licensee performance during an interim 1 l period that the NRC has suspended its Systematic Assessment of Licensee Performance '
(SALP) program. The NRC suspended its SALP program to complete a review of its processes for assessing performance at nuclear power plants. At the end of the review period, the NRC will decide whether to resume the SALP program or terminate it in favor of another process.
The NRC's most recent summary oflicensee performance was provided in a letter of December 12,1996 and was discussed in a public meeting with you on January 10,1997.
I During this period, Unit 2 operated near or at 100 percent power. As of March 13,1998, Unit 2 had run for 169 consecutive days exceeding a previous Unit 2 record run of 143 days. Unit 1
, entered the period at 100 percent power and shut down for refueling outage A6R02 on August l 13. The unit was made critical on October 10 and reached 100 percent power on October 22.
l The unit operated at or near 100 percent power until the reactor tripped on December 25 during troubleshooting of the main turbine hydraulic control system. Unit 1 was connected to the grid on January 2 and remained at or near 100 power for the remainder of the period.
Overall, performance at the plant was consistent. The plant continued to make progress in enhancing station performance. This included completion of activities on Unit 2 to warrant modification of the 1996 Confirmatory Action Letter (CAL) to allow restart. Overall, operating performance for Unit 2 was very good, with no notable transients occurring. Operators generally performed well during routine operations, as well as during a controlled shutdown of Unit 1, and the heatup of Unit 2 for restart.
Although licensee performance has significantly improved over the past 3 years, the organization continued to be challenged by a very large workload which included completion of the Unit 2 steam ger.erator replacement outage and dealing with emerging hardware issues for Unit 1 which resutted in about a one month forced outage. Also, evaluation of service water
, fouling problems from sea life growth, which resulted in degraded service water heat exchanger
[ performance and contributed to the inoperability of a safety related chiller, challenged the l licensee's organization. Corrective actions to determine and correct the cause of the fouling i
were not prompt and required NRC involvement. In addition, weaknesses were noted in the
- licensee's corrective action process implementation. These problems were identified by the Attachment 2 l
l
?
Quality Assurance organization, however, effective management of these problems was not evident. Other challenges included imp lementation of the work control process implementation and reduction of backlogs.
Performance in the Operations area was consistent. Operators generally performed well during routine operations. However, some configuration controlissues occurred for both units.
Although training and qualification of operations personnel was satisfactory, the results of ongoing training raised concems regarding the effectiveness of the Requalification training program. Management and independent Oversight of the station were effective in enhancing station performance. Management attention to address operator workarounds, control room d aficiencies, and the operations procedure revision backlog was appropriate. However, weaknesses existed in the corrective action process implementation. These problems were identified by the Quality Assurance organization; however, effective management of these problems was not evident. Normal core inspections are planned with some increased emphasis in areas needing inspection attention. Plant performance did not significantly affect pinned l resource allocation.
Performance in the Maintenance area was consistent. The maintenance organization exhibited strong management and teamwork, but continued to be challenged by its planning and scheduling process, emergent work activities, and reduction of backlogs. In addition, j maintenance planning and implementation problems continue to occur during maintenance activities. Unit 1 material condition was good, while Unit 2 material condition was adequate.
Licensee self assessment of maintenance was effective. In addition to normal core inspections, an initiative inspection is planned in January 1999 to review maintenance planning and implementation.
Performance in the Engineering area was consistent. Management continm to provide necessary leadership in important areas. Many programs have been improved but small pockets of weakness still exist. System engineering was effective in resolving most emerging issues. Design engineering has also improved but some engineering products did not address all the technicalissues. An extraordinary number of modifications have been completed to improve plant performance In addition to normal core inspections, two followup engineering inspections are planned in February and March 1999 to reduce the backlog of NRC open items.
Performance in the Plant Support Area was consistent. The radiation protection (RP) program continues to very effectively meet its limited challenges associated with the long term shutdown.
Training proficiency of RP technicians was poor. The licensee has updated the Offsite Dose Calculation Manual (ODCM) parameters and a new individual was assigned responsibility for the program. The licensee has implemented an adequate security program. The overall performance of the plant's emergency response organization to a April 1998 Emergency Preparedness (EP) exercise was good. EP program performance is improving. Performance of the fire protection program, based on resident inspector observations, was adequate. In
! addition to normal core inspections, an radioactive effluents inspection is planned to review the licensee's implementation of the ODCM which includes their offsite dose projection calculation methodology.
i i
l l
I l
I .
l .
Enclosure 1 contains a historicallisting of plant issues, referred to as the Plant issues Matrix 1 (PIM), that were considered during this PPR process to arrive at an integrated view of licensee I performance trends. The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and (licensee name). The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately. Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance. In addition, the PPR may also have considered some predecisional and draft material that does not appear in the i
attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
This material will be placed in the PDR as part of the normalissuance of NRC inspection reports and other correspondence.
This letter advises you of our planned inspection effort resulting from the (plant name) PPR review. It is provided to minimize the rescurce impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite.
Enclosure 2 details our inspection plan for the next 6 months. Also included in the plan are NRC non-inspection activities. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas.
Resident inspections are not listed due to their ongoing and continuous nature.
We willinform you of any changes to the inspection plan. If you have any questions, please contact (DRP Branch Chief) at (telephone number).
i l
(Signed by), Chief Reactor Projects Branch !
Division of Reactor Projects Docket Nos. 50-ABC,50-XYZ License Nos. NPF-0, NPF-00 l
Enclosures:
- 1. Plant issues Matrix
- 2. Inspection Plan cc:
Normal cc list + any additional SALP recipients Distribution:
Normal distribution list +
+ Chief, NRR/ DISP / PIPS
+ Chief, OEDO/ROPMS
+ TBoyce, NRR/ DISP /PIPB l
l I
l I
l
_. ._ _. - _ _ - . . _ _ _ ._ _