ML20207F888
Text
.
u 88f0 UNITED STATES
[
9[*.
' NUCLEAR REGULATORY COMMISSION S
ncclON W g,.
oten au.vu. itusois soin
/
'JUL t 71988 Ger',l emen :
A major NRC program for evaluating licensee performance is The Systemt. tic Appraisal o.f Licensee Performance (SALP) program.
Knowing of your iraerest in this program, I am enclosing for your information, the latest revision of NRC Manual Chapter 0516 which provides the SALP program guidance. 'Within Ragion III, we will begin using the new functional areas set forth in the revision for all SALP report periods which extend beyond the June 6, 1988 effective date of the procedure.
Please let me know if you have questions regarding this procedure.
Sincerely,
.gh ut -E.YhrJ.a.-
Charh's E. Noreitus SALP Board Cnairrean
Enclosure:
As stated See Attached Distribution
)
8809230260 880727
% g 4/ 0 PDR ADOCK 05000010 g
P Di,
7.'
Identical Copies Sent To:
Docket No. 50-315" Docket No. 50-331 Docket No. 50-316-Iowa Electric Light and Power Indiana. Michigan Power Company Company.
ATTN: Mr. Milton P. Alexich/
ATTN: Mr. Lee Liu Vice President President and Chief
~'
Nuclear Operations Division Executive Officer 1 Riverside Plaza IE Towers Columbus, OH 43216 P. O. Box 351 Cedar Rapids, IA 52406 De ket No. 50-440 Doe,et No. 50-441 -
Docket No. 50-282 Docket No. 50-306-The Cleveland Electric Illuminating Docket No. 50-263 Company
~~
ATTN:
Mr. Alvin Kaplan Northern States Power Company Vice President ATTN: Mr. C. E. Larson Nuclear Group Vice President, Nuclear 10 Center Road Generation Perry, OH 44081 414 Nicollet Mall Minneapolis, MN 55401 Docket No. 50-456, 50-457; 50-454, 50-455; 50-373, 50-374; 50-10, Docket No. 50-346 50-237 249;-50-254,-50;265; 50-295, 50-304 Toledo Edison Company ATTN: Mr. Drnald Shelton Commonwealth Edison Company Vice P-esidant ATTN:
Mr. Cordell ReeJ Nuricar Senior Vice President Edisen Plaza Post Office Box 767 300 Madison Avenue Chicago, It 60690 Toledo, Od 43652 Docket No. 50-155 Docket No. 50-483 Docket No. 50-256 linion Elec'.ric Comp 6ny Consumers Power Company ATTN: fir. Donald F. Schrell ATTN:
David P. Hoffman Seninr Vice President - Nuclear Vice President Post Office Box 149 - Mail Code 400 Nuclear Operations St. Louis, M0 63166 232 West Mishigan Avenue Jackson, MI 49201 Docket No. 50-266 Docket No. 50-301 Docket No. S'J-409 Wisconsin Electric Power Company Dairyland Power Cooperative ATTN: Mr. C. W. Fay ATTN: Mr. J. W. Taylor Vice President General Manager Nuclear Power Department 2615 East Avenue - South 231 West Michigan, Room 308 La Crosse, WI 54601 Milwaukee, WI 53201
(
g
$6
Idencical Copies Sent To:
1:
Docket No. 50-341 The Detroit Edison Company ATTN:
B. Ralph Sylvia
~ Senior Vice President-Nuclear Operations 6400 North Dixie Highway Newport, MI 48166 Docket No. 50-305 Wisconsin Public Service Corporation ATTN: Mr. D. C. Hintz Vice President Nuclear Power-700 North Adams Post Office Box 19002 Green Bay, WI -54307-9002 s
RIII ORIGINAL SIGNED BY C. E. NOREUU3' Norelius/mnj e
m
/
,,i.
T 1
l A
e
. -~ s - ~ ~. ~ - - - - -.. -. -
i
~
M 4
{
~
- i Identical copies have.been sent to all licensees.
If you need any additional.
information,pleasecall'me.(Marianne Meenan)- 388-5519 or Chad McCormick-5654-3 x
M. Meenan-Region III i
i t
{.
t t
a b
I
- i t
3.
ri.
/~P 4
4 i
t I
3.
i i
l
(
y
\\
f" U.S. NUCLEAR REGULATORY COMMISSION NRC MANUAL Volume: 0000 General Administration Part : 0500 Health and Safety NRR CHAPTER 0516 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-01 COVERAGE AND BACKGROUND This chapter and its appendix describe the basic structure and overall proce-dures for implementation of the NRC program to assess licensee performance.
This program applies to all licensees of power reactors with operating licenses or construction permits.
The Systematic Assessment of Licensee Performance (SALP) is an integrated agency effort to collect and evaluate available agency insights, data, and plant / site basis in a structured manner in order to other information on a assess and better understand the reasons for a licensee's performance.' Unac-ceptable performance is addressed through NRC's enforcement policy and the implementation of this policy should not be delayed to await the results of a SALP.
Compliance with NRC rules and regulations satisfies the minimum re-quirements for continued operation of a facility; the degree to which a li-censee exceeds regulatory requirements is a measure of the licensee's commit-ment to nuclear safety and plant reliability.
The SALP process is used by the NRC to synthesize its observations of and
~
insights into a licenste's pelforrr.anca and to identify common themes or symp-toms.
As such, the NRC needs te recognize and understand tha reasons for a licensee's strengths as well ar, weakneues. The SALP process is a means of express!ng NRC velar managemem.'s observations and judgments on licensee performance.
It should not oc limited to focusing on weaknesses, and it is not intended to identify preocsed resolutions or solutions of problems.
The licensee's management le resp:nsible for en'.uring plant safety and establish-ing effective mecn3 to. measure, monitor, and evaluate the quality of all a's-l-
pects of p' ant design, hardware, and operation. The SALP process is intended to further NrtC's understa.1 ding of (1) how the licensee'a management guides, directs, evaluates, and provides resources for safe plant operations, and (2) l how these resources are applied and used. As a result, emphasis is placed on understanding the reasons for a licensee's performance in identified functional areas and on sharing this understanding with the licensee and the public. The SALP process is intended to be sufficiently diagnostic to provide a ration::le for allocating NRC resources and to provide meaningful feedback to a licensee's i
management.
0516-02 OBJECTIVES 021 To improve the NRC regulatory program by providing a mechanism for focusing NRC management's attention on areas of concern.
I l
Approved : June 6,1988 1
SYSTEMATIC ASSESSMENT OF N R C -C 022 LICENSEE PERFORMANCE 022 To assist NRC management in making sound decisions regarding allo-cation of NRC resources used to oversee, inspect, and assess licensee performance.
023 To be instrumental in improving licensee performance by establishi.1g a basis for dialogue between NRC senior management and licensees specifically directed toward problem areas.
024 To provide a mechanism that focuses attention on the overall effectiveness of management including underlying strengths and weaknesses.
0516-03 RESPONSIBILITIES AND AUTHORITIES 031 The Executive Director for Operations (EDO) provides oversight for the activities described herein.
032 The Director, Office of Nuclear Reactor Regulation (NRR):
Implements the requirements of this chapter within NRR.
a.
b.
Monitors the SALP process; evaluates and develops SA P policy, criteria, and methodology; and assesses the uniformity and adequacy of the implementation of the program.
033 The Directors, Offices of Nuclear Regulatory Research (RES), Analy-sis and Evaluation of Operational Data ( AEOD), and Nuclear Materials Safety and Safeguards (NMSS), implement the requirements of this chapter within their re-spective offices.
034 Regional Admi,njstrators:
a.
Implement the requirements of this chapter witnin their respectNe Regions.
b.
With input from the SALP Board, issue the SALP repo*t, eva!uate licensee comments and the adequacy of licensee commitments; issue the final SALP report; and direct reallocation of Regional insipec-tion resources, as appropriate.
c.
Establish a schadule and determine a site for a meeting with the licenses to ensure mutual understanding of the issues c'iscussed in the SALP report.
d.
Provide to the Director, NRR, recommendations for improving the SALP program.
0516 04 EV ALUAIivN FREQUENCY The NRC will normally review and evaluate each power reactor licensee possess-ing an operating license or construction permit every 15 months except in the following instances:
Approved: June 6,1988
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE N R C-0516-05 a.
In those infrequent cases when the Regional Administrator determines that the performance of a particular utility or facility has been clearly superior, the frequency of the SALP evaluation may be ex-tended up to 18 months.
b.
When the Regional Administrator determines that the performance of a particular utility or facility warrants a more frequent evaluation, such as in the case of licensees that were assigned a Category 3 performance rating in several functional areas during the previous evaluation, the period between SALP evaluation should be reduced to I
about 12 months.
When a SALP evaluation will be used as part of a determination of c.
i the readiness for new-plant startups or plant restarts from an l
extended outage or shutdown, a SALP evaluation should be conducted approximately 1 month before the expected milestone date.
d.
When a new operating license is issued, two consecutive,SALP evalua-
~ tions should be scheduled,at approximately 12-month intervals. The first of these two evaluations should be scheduled for completion approximately 12 months after the low-power license is issued. The second of these two evaluations should be completed approximately 12 months later.
Following completion of these two evaluations, a
determination would then be made on whether to place the licensee on a normal SALP schedule.
)
For licensees operating plants at more than one site, or operating plants at one site that are of significantly different designs, or operating plants at one site that may be' in different stages (e.g.,
construct!on stage, pre-operational stage, or power ascension from an extended outage), independent assessments must be performed.
For licensees operating plants at a multinie unit site, one assessment for the functional crea where there is commonality mey be apprepr: ate.
0516-05 EVAL.UAT IUN PROCf.SS Tha evaluation procesti, illustrated in Figure 1, Appendix 0516, page A-2, is summarized as follows:
a.
Conduct of a SALP.
b.
Issuance of the SALP report by the Regional Administrator.
A public meeting with the licensee's management to discuss the as-c.
sessment.
A meeting with the licensee's management will normally be conducted on site when feasible to foster.more widespread understand-ing of the NRC's views.
d.
Consideration of any written respcose received from the licensee.
A final SALP report will be issued and will include the verbatim writ-ten response received from the licensee and any changes to the SALP
)
Approved: June 6,1988
i SYSTEMATIC ASSESSMENT OF j
LICENSEE PERFORMA NCE N R C -0516-06 report based on the Regional Administrator's consideration of the licensee's response.
The final SALP report should be a stand-alone document.
e.
Overview.
The ratings assigned to individual functional areas are only one aspect of the SALP process.
The SALP Board is expected to assess each functional area in such a manner that the SALP Board discussion focuses on understanding the reasons for the observed performance.
The attributes and assassment criteria provided in Appendix A should be relied on to develop a uniform and consistent approach.
After assessing all of the functional areas, the SALP Board is expected to discuss commonalities, if any, among the fur.c-tional areas.
This process of reviewing the summary results from the standpoint of identifying common underlying reasons for the licensee's performance is the basis of the overview. The overview is not a summary statement of the numerical ratings of the individ-ual functional areas.
Rather, the overview is intended to be a synopsis of the underlying reasons, in the view of NRC managers, for both good and poor licensee performance.
With regard to poor
, licensee performance, the overview developed should b,e somewhat specific so that the licensee may be fully aware of the areas in which increased utility management attention is required.
To emphasize topics for consideration beyond the specified functional areas, NRR will identify selected topics for inclusion as part of the overview. Tepics selected will be addressed by all SALP boards for a defined period, and the summary results will be presented as part of the overview.
General guidance regarding the implementation of the SALP is provided in Ap-pendix B.
Specific guidance for the impiarrentation and ceaduct of the SALP process is contained in the operating procedures of each responsible office and Region.
0516-06 FUNCTIONAL AREAS Functional areas represent a groupin; d simila- !!censee activities.
Each funct!onal area evaluateo v.ill be assigned a rating as definea in Sec-tion 0516-08.
Although not all functional areas need be asstissed in a given review, an explanation should ba given in the SALP report if a functicnal area appropriate io a licensee is r.ot evaluated.
The evaluation criteria and asso-clated attributes against which the functional areas are to be evaluated are provided in Appendix A to this chapter.
flote that performance indicators should not be a factor in judgements ebout the effectiveness o* rating in particular SALP functional area.
It is inappropriate to make reference ato performance indicator program results in arriving at a SALP rating.
061 Operatino Phase Reactors Plant Operations.
This functional area consists chiefly of the con-a.
trol and execution of activities directly related to operating a plant.
It is intended' to include activities such as plant startup, power Approved: June 6,1988
e l
SYSTEMATIC ASSESSMENT OF l
N R C-0516-062 LICENSEE PERFORMANCE f.
Engineering / Technical Support.
The purpose of this functional area l
is to address the adequacy of technical and engineering support for all plant activities.
It includes all licensee activities associated with the design of plant modifications; engineering and technical support for operations, outages, maintenance, testing, surveillance, l
and procurement activities; training; and configuration management.
g.
Safety Assessment / Quality Verification.
This functional area includes all licensee review activities associated with the imple-mentation of licensee safety policies; licensee activities related to amendrient, exemption and relief requests; response to generic letters, bulletins and information notices; and resolution of TMI items and other regulatory initiatives.
It also includes licensee activities related to the resolution of safety issues, 10 CFR 50.59 reviews, 10 C F R 21 assessments, safety committee and self-assess-ment activities, analyses of industry's operational experience, root cause analyses of plant events, use of feedback from plant quality assurance / quality control (QA/QC) reviews, and participation in self-improvement programs.
It includes the effectiveness of the licensee's quality verification function in.
identifying and c'orrecting substandard or anomalous performance, in identifying precursors of potential proclems, and in monitoring the overall performance of the plant, h.
Other ( As Needed).
For example, when plants are in extended shut-downs, it may be more appropriate to address shutdown operations in lieu of plant operations.
For readiness assessments, SALP boards may need to consider activities that take place over a shorter in-terval, such as startup testing.
062 Construction phase Reactors a.
Soils and Foundations.
This functional area ir,cludes all activities pertaining to soils and foundations related to the construction of the ultimate heat sink and major structures.
F;ecifically, this covers, as applicable, subgrade investigation and preparation, fill materials and compaction, embankraents, foundations anJ associated laboratory
- testing, and related instrumentation and monitoring systems.
b.
Containment, Major Structures, and Major Eteel_ Supports. This func-tional area includes all activitMs related to the structural con-crete and steel used in the containment (including the basemat), ma-jor structures, and major steel equipment supports.
It covers all aspects of structural concrete (e.g.,
reinforcing steel; concrete batching, delivery, placement, in-process testing, and curing; liner p' ate erectbn and fabrication; and centainment 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, poiar crane, tanks, heat exchangers, etc. ).
Approved: June 6,1988
7 i
SYSTEMATIC ASSESSMENT OF N R C-0516-061. 6 LICENSEE PERFORMANCE operation, plant shutdown, and system lineups.
Thus, it includes activities such as monitoring and logging plant conditions, normal operations, response to transient and off-normal conditions, manipu-lating the reactor and auxiliary controls, plantwide housekeeping, control room professionalism, and interface with activities that support operations.
b.
Radioloaical Controls.
This functional area consists of activities directly related to radiological controls,
including occupational radiation safety (e.g., occupational radiation protection, radioactive radiation field control, radio-materials and contamination controls, logical surveys and monitoring, and as low as is reasonably achiev-able programs), radioactive waste management (i.e., processing and onsite storage of gaseous, liquid, and solid wastes), radiological effluent control and monitoring (including gaseous and liquid efflu-ents, offsite dose calculations, radiological environmental monitor-ing, and confirmatory measurements), and transportation of radioac-tive materials (e.g.,
procurement of packages, preparation for
' shipment, selection and control of shippers, receipt / acceptance of shipments, periodic maintenance of packagings, and point-of-origin safeguards activities).
Maintenance / Surveillance.
This functional area includes all activi-ties associated with either diagnostic, predictive, preventive or c.
corrective maintenance of plant structures, systems, and -components; control, and storage of components, including qualifi-procurement, and maintenance cation controls; installation of plant modifications; of the plant physical condition.
It includes conduct of all survell-lance (diagnostic) testing activities as well as all inservice inspection and testing activities.
Examples of activities included are instrument calibrations; equipment operability tests; pcst-maintenance, post-modification, and post-outagss testing; containment chemistry controls; special tests; inservica leak rate tests; water inspection and performance tests of pumps and valves; and all other Inservice inspection activities.
This functional area includes activities EmerQency Preparedness.
d.
related To the establishment and implementation of the emergency plan and implementing procedures, such as onsite and offsite plan development and coordination; support and training of onsite and offsite emergency response organizations; licensee performance during exercises and actual events that test emergency plans; administration and implementation of the plan (both during drills and actual events);
notification; radiological exposure control; recovery; protective actions; and interactions with onsite and offsite emergency response organizations during exercises and actual events.
e.
Se m ity.
This functional area includes all activities that ensure E. ~ security of the plant, that is, all aspects of access control, recurity checks, safeguards, and fitness-for-duty activities and controls.
I Approved: June 6,1988
b SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE N RC-0516-062.c c.
Pipino Systems and Supports This functional area includes those piping systems described in the licensee's safety analysis report (SAR) that affect the safe opera-tion of the plant.
It includes those activities and quality checks (e.g.,
fabrication, installation, configuration, welding, nonde-structive examination, and preservice inspection) necessary to en-sure compliance with the applicable codes and other requirements specified in the safety analysis report, specifications, and imple-menting procedures.
d.
Mechanical Components.
This functional area covers mechanical components such as pressure vessels, reactor vessel internals, pumps, and valves located in, and attached to, the piping systems described under the preceding functional area. The primary empha-sis is on discrete components rather than piping or systems,
- e., Auxiliary Systems.
This functional area includes those auxiliary systems in the nuclear, facility that are essential for the safe shutdown of the plant or the protection of the health and safety of the public.
It includes systems such as the heating, ventilation, and air conditioning; radwaste; fire protection; and fuel storage and handling systems.
f.
Electrical Eaulpment and Cables.
This functional area includes
)
important 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, i
switchgear, electric racw ays, cable (power, control, and instru-ment), circuit breakers, relays, and other interrupting and protec-tive devices.
Instrumentation.
This functional area covers instrument components g.
and systems that are designed to maasure, transmit, display, record, c
and/or control various piar.t variables and conoitions.
The reactor protection system and the engineered safety features actuation sys-tem are uxamples of covered plant systems. Also included are de-l vices such as sensors, transtr,ittars, signal conditioners, control-l lers and other actu9 ting devices, recorders, alarms, logic devices, l
Instrument air suppfles, racks, and panels.
h.
Enoineerino/ Technical Support.
The purpose of this functionai area Is to address the adequacy of the technical and engineering support l
for all plant activities.
It includes all licensee activities asso-clated with the design of the plant; engineering and technical sup-i port for maintenance, testing, surveillance, procurement, preopera-and startup, and operational activities; training; and con-tional figuration management (including maintaining design bases and safety margins).
1.
Safety Assessment / Quality Verification.
This functional area in-cludes all licensee review activities associated with the implemen-i
)
tation of licensee safety policies; licensee activities related to l
r Approved: June 6,1988
~.
1 SYSTEMATIC ASSESSMENT OF N R C -0516-07 LICENSEE PERFORMANCE exemption and relief requests; response to generic letters and bul-letins; and resolution of TMl items and other regulatory initia-tives.
In addition, it includes licensee activities related to the resolution of safety issues, 10 CFR '50.55 requirements, 10 CFR 21 assessments, safety committee and self-assessment activities, analy-ses of industry's operational experience, use of feedback from plant It QA/QC reviews, and participation in self-improvement programs.
includes the effectiveness of the licensee's quality. verification function in identifying and correcting substandard or anomalous performance, in identifying precursors of potential problems, and in monitoring the overall performance of the plant.
j.
Others ( As Needed).
For reactors in the preoperational phase, func-tional areas listed for either operating phase reactors or construc-tion phase reactors should be selected, as appropriate.
For reactors in the startup phase, functional areas listed for operating phase reactors should be utilized.
0516-07 EVALUATION CRITERIA Licensees 'will be evaluated in the functional areas described ih Sections 0516 061 and -062 using the following evaluation criteria.
Appendix A to this
~
chapter describes a number of attributes for each evaluation criterion and provides guidance on using these criteria to assign a performance rating.
The evaluation criteria are as follows:
Assurance of quality, including management involvement and control; a.
b.
Approach to the Identification 'and resolution of technical issues from a safety s,tandpoint; Responsiveness to NRC initiatives; c.
d.
Enforcement history; e.
Operational and construction events (including response to, anal /-
sls of, reporting of, and corrective actions for);
f.
Staffing (including management); 2nd Effectiveness of training and qualifications program.
g.
0516-08 PERFORMANCE RATINGS The SALp program is a mechanism to assess the quality of licensee activities j
which a licer.see h committed to superior performance it vro the degree m j
should be noted that NRC's standard for measuring licensee performance re-flects the self-improvements in the nuclear industry and is continually in-creasing.
Licensees earning a Category 1 rating in a functional area have justifying some relaxation in NRC clearly demonstrated superior performance, Conversely,' licensees earning a Category 3 rating in a functional oversignt.
area are of concern to NRC and will receive substantial additicns! NRC inter-action and oversight to assure performance improvements.
Approved: June 6,1M8
SYSTEMATIC ASSESSMENT OF N RC-0516-09 LICENSEE PERFORMANCE The functional area being evaluated may have some attributes associated with a rating of Category 1 and others that are aligned with either a Category 2 or 3 rating.
The final rating for each functional area will be a composite rating of the attributes tempered with judgm'ent as to the significance of individual items.
The assignment of a rating is a serious judgment based on a knowledgeable balancing of experiences and safety significance by senior NRC managers and staff.
Statistical or numerical balancing is inappropriate.
The performance categories used when rating licensee performance are defined as follows:
a.
Category 1.
Licensee management 3ttention and involvement are read-ily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance sub-stantially exceeding regulatory requirements. Licensee resources are a'mple and effectively used so that a high level of plant and person-nel performance is being achieved.
Reduced NRC attention may be appropriate.
Licensee management attention to and involv'ement in the b.
Category 2.
The performance of nuclear safety or safeguards activities are good.
licensee has attained a level of performance above that needed to meet regulatory requirements.
Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal levels.
c.
Category 3.
Licensee management attention to and involvement in performance of nuclear safety or safeguards activities are not the sufficient.
The licensee's performance does not significantly ex-Licensee ceed that needed to meet minimal' regulatory requirements.NRC atten-resources appear to be strained or not effectively used.
tion should be increased above normal levels.
The SALP ls not intended to be a substitute for NRC's enforcement policy. En-
!creement action should not await the outcome of a SALP, but should be taken at the time tne unacceptable action (s) or event (s) occur (s),
in this regard, the SALP process can assist NRC management by providing perspective, but it is not a substitute for effective enforcement action.
Where licensees are incapable of meeting minimal regulatory requirements, the affected plants will be shutdown.
0513-09 PERFORMANCE TREND The SALP report may include an appraisal of the performance trend in a func-area for use as a predictive indicator if near-term performance is of tional interest.
Licensee performance during the last quarter of the assessmen' Normally, this period should be examined to determine whether a trend exists.
performance trend should only be used if both a definite trend is discernable and continuation of the trend may result in a change in performance rating.
The performance trend is intended to predict licensee performance during the first few months of the, next assessment period and should be helpful in al-locating NRC resources.
Of particular interest are those licensees with a i
e Approved: June 6,1988
'a SYSTEMATIC ASSESSMENT OF N R C-0516-10 LICENSEE PERFORMANCE Category 3 performance rating and ~ a declining trend.
These situations are to be brought to the attention of senior NRC management (i.e., NRR Office Direc-tor, Deputy Executive Director for Regional Operations, and Regional Adminis-trator).
Determination of the performance trend should be made selectively and should be reserved for those instances when it is necessary to focus NRC and licen-see attention on an area with a declining performance trend, or to acknowledge an improving trend in licensee performance.
The trend, if used, is defined as:
a.
Improving.
Licensee performance was determined to be improving near the close of the assessment period.
b.
Declining.
Licensee performance was determined to be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this pattern.
0516-10 BASIC REQUIREMENTS Applicability.
This chapter and its appendix apply to and must be implemented by NRC Headquarters and Regional Offices.
Approved: June 6,1988
J' SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDtX 0516 APPENDIX A 2
EVALUATION CRITERIA The assessment of licensee performance is implemented through the use of seven evaluation criteria. The criteria provide standard guidance that the NRC shall apply to each functional area to categorize licensee performance.
To provide consister.t evaluation of licensee performance, several attributes associated with each criterion are listed in Table I to describe the characteristics applicable to the three categories.
The seven criteria and their associated attributes will aid the NRC staff in understanding and evaluating licensee performance by identifying the causes and factors appropriate for categorization.
It is not intended that consideration of these attributes influence established programs of the agency. For example, it is not, intended that the staff perform specific inspections to evaluate attributes.
It is expected that during the implementation of established pro-grams, the staff will observe many of the attributes that describe performance.
Awareness and consideration of these attributes should assist the staff in its observation of licensee performance during routine activities.
All of the attributes of the evaluation criteria are not necessarily applicable to each licensee during each SALP period. For example, the observed perform-ance within a functional area may be insufficient to allow consideration in the assessment. However, the evaluation criteria should be considered in the,
evaluation of each functional area to the extent appropriate.
All available information should be analyzed by the SALP Board and the Regional' Administrator, and its significance, whether it be positive cr negative, should If information is scarce or nonexistent, a decision regarding the be weighea.
performance category as it relates to an attribute should not be forced.
s Tables 2 and 3 provide a matrix of functional areas by evaluation criteria that may be useful to the SALP Board in assessing and recording If;ensee performance.
a n
/
a A-1 Approved: June 6,1988
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
'lRC APPENDIX 0516 FIGURE 1 SALP EVALUATION PROCESS SCHEDULAR GOALS l
End of Assessment Period IL 37 SALP Board Within Preparation 30 days If SALP Board Meeting U
17 SALP Within Repodissuance 30 days U
if Meeting Within with the Licensee 30 days if it Within Licensee
Response
30 days II 17 SALP oport 3
aYs l
Issuance Approved: June 6,1988 A-2
~
~..
EVALUATION CRITERIA AND ATTRIBUTES FOR ASSESSMENT OF LICENSEE PERFORMANCE TABLE 1 1.
Assurance of Quality, Including Management Involvement and Control rg Category 1 Category 2 Category 3
- E a.
There is little evidence of There is consistent evidence a.
There is evidence of prior d
of prior planning and planning and assignment of prior planning r.nd assignment a.
i assignment of priorities; priorities; procedures for of priorities; procedures for gO procedures for control of control of activities are control of activities are poorly n>
activities are well stated, stated and defined.
stated or not well understood.
gg controlled, and explicit.
b.
Policies are well stated, b.
Policies are adequately stated b.
Policies are poorly stated, zE om disseminated, and under-and understood.
poorly understood or
- C nonexistent.
standable.
c.
Decisionmaking is con-c.
Decisionmaking is usually at a c.
Decisionmaking is seldom at a Q
sistently at a level that level that ensures adequate level that ensures adequate ensures adequate management management review.
management review.
Te 1eW.
d.
Corporate management is fre-d.
Corporate management is usually d.
Corporate management is seldon J.
quently and effectively involved in site activities in or ineffectively involved in involved in site activities.
an effective manner.
site activitias.
e.
Engineering evaluations are e.
Engineering evaluations are Engineering evaluations are consistently technically generally adequate and records frequently inadequate and e.
ad~;uate and records and and plant. performance data are records and plant perform nce plant performance data are gesserally complete, well data are not complete, well complete, well maintained, maintained, and available.
maintained, or available.
E and available, u
f.
Corrective action is f.
Corrective action is usually f.
Corrective action is not timely y
effective as indicated by taken but may not be effective or effective and generally ad-j g
lack of repetition of in correcting the root cause dresses symptoms rather than o
events.
of the problem, as indicated by root caus2s, as indicated by c casional repetition of events.
repetition of events.
j c
3 y
g.
Safety review committees g.
Root cause analyses and s~ elf-g.
Corporate management does not o
(ISEG, onsite, offsite, assessments are occasionally appear to rely on self-assessment X
f, etc.) and feedback from evident and sometimes result to ensure quality in activities.
S i
g QA/QC actisities are used in improvements.
g, to provide critical self-assessments to the corporate I
management and to improve work activities.
e TABLE 1 (Continued) 2.
Approach to the Resolution of Technical Issues from a Safety Standpoint Zxn v
3 Category 1 Category 2 Category 3 n
a.
Clear uncerstanding of a.
Understanding of issues is a.
Understanding of issues is issues is demonstrated.
generally apparent.
frequently lacking.
Z O
c E
b.
Conservatism is routinely b.
Conservatism is generally b.
Minimum requirements are met.
X exhibited when potential for exhibited.
S 9
safety s gnificance exists.
g, h
c.
Approaches are technically c.
Approaches are viable and c.
Approaches are often viable, but sound and thorough in almost generally sound and thorough.
lacking in thoroughness or depth, all cases.
l d.
ISEG and safety review d.
Problems often recur before d.
Critical self-assessment is committees are routinely and they are effective 19 resolved.
lacking; therefore, problems effectively used to identify are not identified until they underlying problems befare become evident.
l they become issues.
s e.
Resolutions are timely in e.
Resolutions are generally e.
Resolutions are often delayed.
almost all cases.
tis:ely.
f.
10 CFR 50.59 reviews are f.
10 CFR 50.59 reviews are done f.
10 CFR 50.59 reviews are not well well documented and demon-well but frequently lacking in documented and reflect a minimal strate a technical documented detail or technical analysis.
a rationale.
technical basis.
rg n>
~~4 GB m
my m$
V l
m N W mm Og s
i mm EZ
> -1 O
m, j
e e
w a-
TABLE 1 (continued) 3.
Responsiveness to NRC Initiatives CQ n
D*m Category 1 Cateery 2 Category 3 E
Res.nonses generally are timely:
a.
Extensions of time are m>g a.'
Deadlines a s met.
a.
frequently required.
v-b.
Resolution of issues is b.
Few longstanding regulatory b.
Longstanding regulatory issues Ey timely.
issues are attributable to are attributable to licensee.
@m IG licensee.
>m c.
Responses are technically c.
Responses are viable and c.
Responses are often viable, but 8M mZ sound and thorough in almost generally sound and thorough.
lacking in thoroughness or depth.
all cases.
on d.
Acceptable resolutions are d.
Acceptable resolutions are d.
Considerable NRC effort or proposed initially in teost generally proposed.'
repeated submittals are needed to obtain acceptable resolutions.
cases.
MRC initiatives and policies' Implementation of MRC initiatives e.
Implementation of MRC e.
e.
initiatives and policies are feelemented within an and policies is frequently is timely and effective acceptable timeframe, but delayed or not done in a thorough vi and licensee consistently licensee usually relies on MRC manner.
meets expectations with to establish an adequate scope, regard to schedule or content, or timeframe.
content.
2 V
2<
2 o
T' c
a z
on 1
8
=
a; l
sy TABLE 1 (continued)
' z 4.
Enforcement History xo j
n Category 3 3
v Categorv 2 3
Category 1 Multiple major violations or h
a.
a.
Major violations are rare z
and are not indicative of and may indicate minor program-programmatic breakdown is a.
Major vio mtions are rare 9
O indicated.
matic breakdown, programmauc breakdown.
b.
Minor vio'ations are not b.
Multiple minor violations b.
Minor violations are repetitive g
- q j
and indicative of programmatic g
repetitive and not indicative or minor programmatic breakdown
-breakdown.
is indicated.
of programmatic breakdown.
Corrective action is delayed or Corrective action is timely c.
. Corrective action is prompt c.
not effective.
c.
and effective in most cases.
and effective, d.
Root cause analyses are d.
Root cause analyses are d.
Root cause analyses are super-ficial, deal only with evident effective as evidenced by frequently ineffective.
problem, and are not effective lack of recurrence.
in preventing recurrence.
Ye (A
(n
-4 b
n>
A -4 mmy m$
V m
Mm "f1 LA
~
Og mm 3Z
> -t ZO O
- m '
O
__m
\\--
TAB:.E 1 (continued) r_- m g
5.
Operational and Construction Events n
D*m Category 3 Category 2 E
Category 1 Frequent significant opera-my Occasicnal significant opera-
..a.
Few significant operational tional or construction events, mO a.
v-tional or construction events, a.
or construction events, at-attributable to causes under the attributable to causes under the tributable to causes under licensee's control, have occurred licensee's control, have occurred ny that are relevant to this
@m
- te licensee's control, have that are relevant to this IG occurred that are relevant functional area.
functional area.
>m to this functional area.
b.
Events are promptly and b.
Events are reported in a timely b.
Event are frequently reported zg mz late or not completely.
manner; some information is
-completely repor'ed.
occasionally lacking.
on Events are poorly identified or Events are accurately identi-c.
Events are properly identi-analyses are marginal; events c.
c.
fled and analyzed.
tied, but some analyses are are associated with program-marginal.
matic weaknesses.
a d.
Deficiencies in man-d.
Deficiencies in man-machine d.
Deficiencies in man-machine interface result in personnel interface repeatedly result in machine interface (e.g., in errors, b' t effective corrective personnel errors.
u human engineering oesign and sctions Are implemented.
procedures) rarely result in personnel errors.
V Z
a
- D e
g u
C Z
E X
8$
I 8,
a
s TABLE 1 (continued)
Z 6.
Staffing (Including Management) m n
13
}
Category 1 Category 2 Category 3 p
13 v
a.
Positions are poorly identi-
?
Key positions are identified, 1
cp a.
Positions 4re identified, a.
and authorities and responsi-and responsibilities are fied, or authorities and respon-
=
sibilities are ill defined.
52 bilities are well defined.
defined.
x t-E Vacant key pusiticns are b.
Vacant key positions are usual-b.
Key positions are left vacant for g
b.
filled on a priority basis.
ly filled in a reasonable time.
extended periods of time.
g; Very little expertise is avail-Expertise is usually available 5k c.
Expertise is available with-c.
in staff; outside consul-within the staff; consultants able within the staff; there is c.
- 1t2.re rarely needed; are appropriately used; staffing excessive reliance on consultants;
- ?'.ng is ample as indi-is adequate as indicated by staffing is weak or minimal as c
d by control over backlog occasional difficulties with indicated by excessive backlog or and overtime.
Dacklog or overtime.'
overtime.
d.
Experience levels for manage-d.
Erperience levels for management d.
Experience levels for management ment and operations personnel and operations personnel meet and operations personnel are be-exceed commitments made by commitments made by licensee at low commitments made by licensee licensee at time of licensing, time of licensing.
at time of licensing.
co m
-<m
-4 CE n$
C -4 Go m
mp Vm m m Mm Ti m Og Dm KZ
> -1 nOm m
G
~
TABLE 1 (continued) 7.
Effectiveness of Training and Qualification Program Cy niu Category 1 Category 2 Category 3 zd
- I>
a.
Training anc qualificat:on a.
Training and qualification pro.
a.
Training and qualification y
program makes a positive con-gra contributes to an adequate program is found to be the major 3O tribution, commensurate wi?h er:derstanding of work and fair contributing factor to poor procedures and staf.ing, to adt.crence to procedures, as understanding of work, as indi-my the understanding of work and indicated by a modest number of cated by numerous procedural
@m adherence to procedures, as personnel errors.
violations or personnel errors.
g*
indicated by few personnel gy om errors.
mz b.
Training program is well b.
A defined program is implement-b.
Program is either lacking, defined and implemented with ed for a large portion of the poorly defined, or ineffectively dedicated resources and a statf.
~
applied fon a significant segment of the staff.
means for fee 6ack of expe-rience program is applied to nearly all the staff.
>a c.
Inadequate training could c.
Inadequate training could occa-c.
Inadequate training could rarely be traced as a root stor. ally be traced as a root regularly be traced as a root cause of major or sinct events cause of major or minor events cause of major or minor events or problems oct.crring during or problems occurring during or problems occurring during the rating period.
the rating period.
the rating period.
d.
Proc.edures and pc-licies d.
Procedures and policies are d.
Procedures and policies are are followed.
rarely violated.
occasionally violated.
E a
z i
t" 8
b X
e E
o
SYSTEMATIC ASSESSMENT OF NRC APPF.NDIX 0516 LICENSEE PERFORMANCE APPENDlX B SALP IMPLEMENTATION I
1.
SALP BOARD ASSESSMENT A.
SALP Board Preparation Each Region shall:
l Issue a memoraindum establishing the assessment period, the due date 1.
for SALP Board input, the date of SALP Board meeting, and the expected date of the meeting with the licensee for all facilities The within the Region scneduled for a SALP during the fiscal year.
Regions shall send this memorandum to NRR, NMSS, AEOD, RES, and The applicable the EDO by the end of the preceding fiscal year.
NRC SALP database also should be updated as anpropriate. Changes to SALP schedules shall be provided to these e fices (and the SALP database).
SALP Board members should be not. led promptly of un-avoldable scheduling problems to facilitate coordination of alter-native meeting detes.
2.
Prepare a draft SALP iaport.
Integrate SALP report inputs. NRR shall provide written input a.
for each functional area as appropriate.
b.
Prepare the Supporting Data Summary section of the report.
(See Exhibit 1 for format.)
Prepare a performance analysis for each of the functional areas.
c.
Issue a draft SALP report to SALP Board participants before Note that this draft should not d.
the SALP board meeting date.
contain recommended licensee performance ratings.
l B.
SALP Board Meeting The SALP Board meeting, which should be held within 45 days of the end of the assessrrent period, will be conducted in accordance with 1.
the Region's SALP Implementation procedures.
i Board is multidisciplinar, in nature 2.
The composition of the SALPin an integrated assessment of licensee l
and is intended to result Specification of the Board's voting members is rot 2
meant in any way to limit presentations before the Board by other performance.
I staff members when appropriate.
Rather, the staff member e NkC a functional area should be requested to associated with closely discuss their views w'th the SALP Board.
i i
j B -1 Approved: June 6,1988
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE Voting members are expected to participate in Board discussions of each functional area in order to contribute effectively to the assessment of the licensee's performance and the identification of common themes and symptoms of that performance.
As a result, SALP Board deliberations should be oriented toward reaching a consensus view when possible.
The SALP Board composition shall be as follows with each member having a vote:
a.
SALP Board Chairperson (Regional SES-level manager);
b.
Senior Resident inspector; c.
NRR Project Manager d.
NRR SES-level manager; e.
Regional Projects Division
- Director, Deputy
- Director, or Branch Chief; and f,.
Regional Specialist Division
- Director, Deputy Director, or Branch Chief (at least one from each Specialist Division);
g.
Others as designated by the Regional Administrator for any specific Board.
A Board quorum will consist of a minimum of six persons, with the Chairperson an SES-level manager.
Generally, there should be no more than nine persons on the Board.
To enhance consistency in approach, Regional Administrators are encouraged to arrange for the periodic participation on SALP boards of SES-level managers from other Regions.
3.
During the SALP Board meeting:
a.
The SALP Board members shall review and discuss the draft SALP report.
They shall ensure that a conclusion has been reached regarding licensee performance within each functional area or alternatively confirm that sufficient information is not available to support a conclusion regarding licensee performance.
They shall ensure that the discussion of perfor-mance within each functional area identifies common themes or symptoms of that performance if known.
I b.
The SALP Beard members shall evaluate licensee performance in each functional area after considering the evaluation criterla with their associated attributes listed in Appoidix A, Table 1.
Tables 2 and 3 may be used by the SALP Board members to as-sist them in rating the licensee.
The functional area rat-ings wlil be determined by a majority vote of the Board's voting members.
Approved: June 6,1988 B-2
SYSTEMATIC ASSESSMENT OF NRC APPENDlX 0516 LICENSEE PERFORMANCE
)
The SALP Board should recommend changes to the NRC inspec-c.
tion program to be implemented at the specific facility, as appropriate.
d.
The SALP Board shall identify weaknesses and/or recommend areas for licensee consideration so that improvement iri per-formance can be addressed, The SALP Board Chairperson shall ensure that the licensee's e.
overall performance is discussed and assessed with an emphasis on identified strengths and weaknesses.
Following the SALP Board meeting, the SALP Board Chairperson shall 4.
provide to the Regional Administrator a SALP Board report with its recommended ratings and overview.
The Regional Administrator may make substantive changes to the content of the report before it is issued to the licensee.
If the changes are made, the Regional Administrator should so inform the Board Chairperson.
II.
ISSUANCE OF REPORT The Regional Administrator shall sign and issue the SALP reoort (Exhibit
- 1) to the licensee within 60 days from the end of the assessment period.
Coples of the report should also be provided to the offices of the EDO, the Direi: tor of NRR, the Commissioners, and the NRR SALP Coordinator, report will be distributed on a timely The letter transmitting the SALP basis as a standard docket item to the NRC Public Document Room, the appropriate Local Public Document Room, and the institute of Nuclear Power Operations (Record Center, institute of Nuclear Power Operations; 1100 Circle 75 Parkway; Suite 1500; Atlanta, GA 30339).
Each report will be assigned an inspection report number.
The transmittal letter should include:
1 A characterization of overall safety performance consistent with Overview section of the SALP report.
The transmittal letter the strive to characterize NRC's confidence in or concern with should the licensee's performance and the underlying reason (s) thereof.
2.
Areas or issues that warrant discussion during the meeting with the licensee.
A request for the licensee's written comments on and amplification of, as appropriate, the SALP report within 30 days after the meeting 3.
with the licensee.
For all functional areas rated as Category 3, the transmitfal letter must require a licensee response providing planned corrective actions to achieve improved performance.
Ill. MEETING WITH LICENSEE A public meeting with the licensee's management to oiscuss the issuance of the draft SALP report.
A.
General.
assessment will be held following ite, if fessible, to foster more wide-The meeting will be conducted on spread understanding among the ncensee's staff of the NRC's views.
B3 Approved: June 6,1988
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 UCENSEE PERFORMANCE B.
Meeting Preoaration 1.
The Region shall provide notification of the meeting with the licensee with the s&me distribution as for issuance of the SALP report (see Appendix B, Section 11).
2.
The licensee should be encouraged to have the following management representatives participate in the meeting:
Senior corporate management representative; a.
b.
Management officials responsible for the major functional areas; and c.
Site Manager.
C.
Meeting with Licensee 1.
The meeting should be conducted within 90 days of the end of the
- assessment period.
2.
NRC representatives for this meeting should typically include the following:
The Regional Administrator or Deputy Administrator (especially a.
if licensee performance has been rated as Category 3, or Category 2 with a declining trend);
b.
SALP Board Chairperson; c.
Responsible Replonal division d! rector (s), branch chiefs, or section chiefs, as appropriate; d.
NRR Project Manager and/or designated NRR SES-level manager; Resident inspector and/or assigned inspectors; and e.
f.
Public Affairs Officer, when tredla interest is anticipated.
3.
The Regional Administrator, Deputy Administrator, or Project Division Director will chair the meeting ar d discussions of the adequacy of the licensee's management control systems.
These meetings are intended to provide a forum for a candid discussion of issues rr.lating to the licensee's performance.
Those aspects of the licensee's operation that need improvement will be identified, as well as the positive aspects of the licensee's performance.
The licensee also will be given the opportunity to provide comments the report in writing within 30 days after the meeting.
Only on written comments from the licensee must be subsequently addressed by the Regional Administrator.
Approved: June 6,1980 B-4
f SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 4.
SALP management meetings with the licensee should be public meet-ings, unless portions of the meetings involve discussion of matters that are not required to be placed in the public domain pursuant to 10 C F R 2.790.
For those portions, the meeting must be closed.
Members of the public should be treated as observers.
Adequate notification of the SALP meeting should be accomplished by the timely distribution to the Public Document Room of the letter scheduling the meeting to the licensee, with copies to the carties on the service list for the appropriate docket.
IV.
SALP REPORT FORMAT AND CONTENT A.
General The SALP report is considerad to be a final report once the Regional Administrator has signed the transmittal letter and sent the report to the licensee following the meeting with the licensee and consideration of the licensee's written response, if any.
For distribution purposes, the draf t SALP report transmitted to the licensee before the meeting with the licensee is not considered "predecisional."
B.
Multiple Facility Licensees For multiple facility licensees, such as Duke Power Co.,
Tennessee Valley Authority, and Commonwealth Edison, the S.*.L P package may address more than one site.
However, each site shall have a separate SALP t-eport (see Section 0516-04).
C.
Report Format and Content The SALP report shall be prepared in. general conformance to the guide-lines in Exhibit 1.
V.
FINAL SALP REPORT A.
General The Regional Administrator shall issue the final SALP report within 30 days of receipt of the licensee's written comments or planned actions.
This report will receive the same distribution as correctiu the draft SALP report transmitted to the licensee prior to meeting with the licensee.
B.
Final SALP Report The final SALP report shall consist of:
1.
The sat P report with any changes made after the meeting with the licensee.
2.
A summary of the meeting held with the licensee concerning the SALP
- report, B-5 Approved: June 6,1988 e
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE 3.
A copy of the written comments received from the licensee.
4.
N R C's conclusion regarding the acceptability of the licensee's planned corrective actions, if required.
5.
The conclusions of the Regional Administrator based on considern-tion of the licensee's comments and planned corrective actions.
C.
Changing the Draft SALP Report Any changes made to the draft SALP report after the meeting with the licensee must be done using the following procedure (an example of each of the items mentioned below is shown in Exhibits 2, 3, and 4).
1.
Include an errata sheet (Exhibit 2) as a separate enclosure to the Regional Administrator's cover letter denoting the change and the basis for the change.
2.
Add the corrected page (Exhibit 4) to the report, leaving the origi-rim page (Exhibit 3) in the report.
3.
Make a diagonal line through the originti page, and reference the errata sheet.
l l
l l
B-6 Approved:
June 6, 1988
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 TABLE 2 EVALUATION MATRIX FOR OPERATING PHASE FUNCTIONAL AREAS
~
.5 3
1 c
1 N
r 0
b c
0 Es *s 5 b
?
8 93 e
2 ts
'E um g
g z
In h
X d in I }a$
~
e se o.
E hb h
Nh o
bu tt 8
81 a
58 Plant Operations Radiological Controls t
l Malrdenance/ Surveillance i
Emergency Preparedness Securtty EngineerInrjiechnical Support Safety Assessment /Ouality Vermcation i
~
l Othpr
[
]
l B-7 Approved: June 6,1988 l
)j,
1'{!):!
5 e
6 e
$wm rm2 om m* =mQomr*Enm mh mr$-
r C2 zmn >=v= ?x o5*
yyfma Qyrc>a Oz EyymE 03 oOn(4@oH6z n
NZ>m"mCzO 52>r $m>M n
d o
n n
it a
o c
g i
tu u
n C
r i
lo t
n R
s t
e N
y n
ia y
s r
o T
r i
Rs o
o la e
C t
t u
du s
f Q
ns s
d o
i as s
H n
e a
s s i
f sn o
nl n
tn oa e
a eo l
t c v
e nt i
e i
n r
m o
ea i
c ai se n
c n g
vc a
ih nv e
it ii s~
n tf r
ic oi c
ai f
ci t
r i
rn l
e pa o
c f
u t
ea f
s nT si f
e a
f u
s e
ei n
~v t
t f
A do RI E
OE S
EQ n
f i
.&. 3" e&aoa n
o8 =.$.n ?v m=RE, '.E f o m5* mcE$.
iia = =
3= :a mB,od m3,.a o88oIG
>5=s2 m ni=
mFo =.2 mfj.o.& oE&.
5e,c!a.e8 ma =e= a3I5E mcBo2 r
=E.2.>::..I c@".x<*s5.c0 g2.
m.
- o,ea. ra *
"g=
il(\\l ljll!'l
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE EXHIBIT 1 (continued) each functional area and across functional areas.
Discuss performance trends, if evident.
In addition, provide a table of performance ratings as indicated below.)
[ Functional areal l Rating last period]
1R_ating this period)
[ Trend, if Any]
B.
Other Areas of interest These
[ Provide an overview of licensee performance in each topic area.
topic areas are determined by the Director, NRR and/or the Regional Administrator.}
II:. CRITERI A Licensee oerformance is assessed in selected functional areas, depending on whether the facility is in a construction or operational, phase.
Functional areas normally represent areas significant to nuclear safety and the environment.
Some fur.ctional 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.
The following evaluation criteria were used, as applicabie, to assess each functional area:
1 Assurance of quality, including management involvement and control; 1.
2.
Approach to the resolution of technical issues from a safety standpoint; 3.
Responsiveness to NRC initiatives; 4.
Enforcement history; Operational and construction events (including response to, analyses 5.
of, reporting of, and corrective actions for);
6.
Staffing (including management); and 7.
Effectiveness of training and qualification program.
the NRC is not limited to these criteria and others may have
- However, been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories.
The definitions of these performance categories are as follows:
)
B-11 Approved: June 6,1988 i
4 SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE EXHIBIT 1 (continued) 1.
Category 1.
Licensee management attention and involvament are readily evident and place emphasis on superior performance of nu-clear safety or safeguards activities, with the resulting perform-ance substantially exceeding regulatory requirements, Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved.
Reduced NRC attention may be appropriate.
2.
Category 2.
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities is good.
The licensee has attained a level of performance above that needed to meet regulatory requirements.
Licensee resources are adequate and reasonably Lilocated so that good plant and personnel perform-ance is being achieved.
NRC attention may be maintained at normal levels.
3.
Category 3.
Licensee management attention to and involvement in performance of nuclear safety or safeguards activities are not the sufficient.
The licensee's performance does not significantly ex-ceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC atten-tion shoulo be increased above normal levels.
IV. PERFORMANCE ANALYSIS A.
[ State functional area being discussed) 1.
Analysis
[This analysis should concent. ate on the adequacy of the licensee's management control systems and assurance of quality, personnel performance and staffing, effectiveness of training and qualification program, enforcement histo;y, and the degree to which the licensee is committed to superior performance.
T his section should not necessarily reiterate or ta'oulate the information and data that contribute to the analysis. Rather, it should be a summary of the supporting rationale.
Informa-tion and data should be provided in Section V of the this re-por t.
Licensee performance should be discussed in light of the evaluation criteria anc associated attributes both to en-sure completeness and to compare licensee performance across functional areas.
The analysis is intended to be sufficiently diagnostic to provide a rationale for allocating NRC resources ard to orovida meaningful guidance to licensee's management.]
Approved: June 6,1988 B-12
SYSTEMATIC ASSESSMENT OF NRC APPEN' DIX 0516 LICENSEE PERFORMANCE EXHIBIT 1
[ DRAFT OR FINAL] SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION REGION [ number]
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (Inspection Report Number]
(Name of Licensee)
(Name of Facility and Docket Number]
(Assessment Period)
B-9 Approved: June 6,1988
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE EXHIBIT 1 (continued) 1.
INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on y
a periodic basis end to evalutte licensee performance on the basis of this information.
The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.
It is intended to be sufficiently diagnostic to provide a
- tional basis for allocating NRC resources and to provide meaningful feedback to the licensee's man-agement regarding the NRC's assessment of their fa:ility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
[date), to review the observations and data on performance, and to assess licensee performance in accordance with Chapter NRC-0516, "Systematic Assessment of Licensee Performance."
The guidance and evaluation cri-teria are summarized in Section 111 of this report.
The Board's findings and recommendations were forwarded to the NRC Regional Administrator for appr6 val and issuance.
This report is the NRC's assessment of the licensee's safety performance at (name of facility} for the period [date] through [date}.
The SALP Board for (name of facility} was composed of:
[ List SALP Board members' names and titles)
A.
Licensee Activities
[ Provide a factual outline of major licensee activities, such as major outages, power limitations, important license amendments, and significant modifications.)
B.
Direct Inspection and Review Activities (Provide a factual summary of major direct inspection and review activities performed by resident inspectors, Region-based staff, and Headquarters staff in each functional area.
This is not intended to be a summary of each inspection or review performed, but rather of those that had a significant effect on the results discussed in Section IV of this report.]
11.
SUMMARY
OF RESULTS A.
Overview
[ Provide a narrative overview summary of the overall effectiveness of licensee's management including underlying strengths and weaknesses.
This summary should synthesize information on licensee performance and identify common themes ur symptoms of that performance, both within Approved: June 6,1988 B-10
j.
SYSTEMATIC ASSESSMENT OF -
NRC APPENDIX 0516 LICENSE E - PER FORMANC E EXHIBIT 1 (continued) i 2.
Performance Rat no
[ Provide the performance rating (Category 1, 2, or 3) for each functional area considered, if appropriate, include a trend assessment (improving or declining), characterizin licensee performance near the close of the assessment period.]g 3.
Recommendations
[ Include any general or specific NRC recommendations pertaining to either licensee management's attention or the level of NRC inspection activities in e functional area.
Note that even in the absence of a recommendation to vary the inspection effort, the Regional Office may do so at its discretion on the basis of appropriate NRC Manual chapters.]
V.
SUPPORTING DATA AND. SUMMARIES A.
Enforcement Act,is sty
[ Include Table 1, "Enforcement Activity" - use footnotes to identify any functional areas associated with civil penalties or orders.]
B.
Confirmation of Action Letters (Provide a summary.]
C.
Other (Diacuss any other issues at the discretion of the SALP Board.]
J B -13 Approved: June 6,1988
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 EXHIBIT 1 (continued)
TABLE 1 ENFORCEMENT ACTIVITY NO. OF VIOLATIONS IN SEVERITY LEVEL FUNCTIONAL AREA V
IV III II I
TOTAL Footnotes:
Approved:
June 6, 1988 B-14
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC APPENDIX 0516 EXHIBIT 2 ERRATA SHEET SALP BOARD REPORT ERRATA SHEET PAGE LINE NOW RE ADS SHOULD READ 5
24 operator's coonitive decision operator's decision Basis: The word cognitive" was deleted to avoid further problems in inter-preting its meaning.
As used, the word was intended to mean that the operator, as the cognizant individual on shift, knew the operating requirem6nts of the Technical Specification but made a conscious deci-sion to operate the plant in a manner which he/she believed was equivalent to the requirements it was not Iretend'id to mean that the operator took actions in total disregard of the Technical Specifica-tiori objectives.
)
B 15 Approved:. June 6,1988 i
~
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 UCENSEE PERFORMANCE EXHIBIT 3 ORIGINAL PAGE
- 0) Severity Level IV - Failure to take timely and proper corrective action follwing the f ailure if a cold leg RTD (50 000/81-24).
(11) everity Level VI - Failure to make a 30 day report on a degraded b
voltage relay (50 000/81 26).
Six of the encompliances 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 SectNn 4, Surv ance.
Nine L(R'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 thirty percent in the last quarter indicat-n rate in the period. Six of the nine were ing an increasing occur for incorrect valve or 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 cognitive decision to operate a system (charging and$
and containment isolation, respectively) in a manner not all he Technical Specifications.
' ring the evaluation period, Unit 1 experienced nine automatic tr four caused by operator error and five quipsent failure.
Of the four caused by errors, two were due to i ctly conducted instrument surveillance tests, one to an incorrect va ineup on the steam side, and the last to unfamiliarity with turbine 1s.
Unit 2 experienced nine reactor trips, one bei anually initiated turbine trip. Four of the trips were related to per nnel errors; two by loss of vacuum in the pain condenser, one resulted om a low steam generator level, and one resulted from a turt>ine valve misalignment.
No significant safety concern is associated with these tr s and each was reviewed to verify proper safety system operation an operator actions.
Various operating problems and events identified during the p tod l
resulted in an enforcement meeting on August 4,1981, with foil up meeting on August 4,1981, with followup meetings on November 2,19 5
Approved: June 6,1988 B-16 e--
SYSTEMATIC ASSESSMENT OF NRC APPENDIX 0516 LICENSEE PERFORMANCE EXHIBIT 4 CORRECTED PAGE (10) Severity Level !Y - Failure to take timely and proper corrective i
action following the failure of a cold leg RTD (50-000/8124).
(11) Severity Level VI - Failure to make a 30 day report on a degraded bus voltage relay (50-000/8126).
Six of the noncompliances were for failure to make required reports or to make timely reports, four for failure to follow procedures, and one for incomplete documentation. One noncompliance for failure to properly report a breach in containment, Iten (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 I and three at Unit 2.
Sixty percent of these occurred in the last half uf 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) we,. of particular concern since they reflected a licensed operator's decision to operate a system (charging and letd wn 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, tko were due to incorrectly conducted instrument surveillance tests, om to an incorrect valve lineup on the steam side, and the last to unfant11arity 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 aisalignment.
I No significant safety concern is associated with these trips and each was reviewed to verify proper safety system operation and operator I
actions.
l l
Various opetating problems and events identified during the period resulted in an enforcement meeting on August 4,1981, with followup seating on August 4,1981, with followup meetings on November 2,1981 5
B-17 Approved: June 6,1988 i
I
-