ML20237G509
| ML20237G509 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 10/10/1986 |
| From: | Lydon J BOSTON EDISON CO. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20237G482 | List: |
| References | |
| FOIA-87-394 86-158, NUDOCS 8708140103 | |
| Download: ML20237G509 (89) | |
Text
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l BOSTON EDISON E xecutive Of hces j
800 Boybton street Boston, r/ massachusetts 02199 l
James M. Lydon Chief operatmg Of hcer l
October 10, 1986 l
BECo Ltr. #86 158 l
l Dr. Thomas E. Murley Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue - Region 1 King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293
Dear Dr. Murley:
i This letter revises our committed completion date for HVAC Vital Area barrier modifications.
Originally the completion date was scheduled for 11/1/86 as 1
documented by NRC Inspection Report 86-08 and as reported on the most recent schedule submitted to NRC Management at the 9/9/86, six week progress meeting.
As discussed between Mr. Gregory Smith of your staff and Boston Edison staff personnel on 9/3/86, the revised completion date is January 31, 1987.
The attached schedule reflects the revised completion date.
It is our understanding that this revised commitment date is acceptable to the NRC.
Reasons for the revised date include the following:
Plant design Change (PDC) 86-31 " Fire Damper Modifications" wnich is impacting the installation of 20 of the 32 HVAC Vital Area barrier 1
modifications (the other 12 HVAC modifications are complete);
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J a work stoppage by union personnel and a subsequent labor action by l
contract personnel which delayed the schedule approximately eight weeks.
If you have any questions or comments regarding this letter, please call me
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directly.
Respectfully submitted, 2 iw O'l cln j j J.M. Lydon PJH/ko i
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NUCLEAR REGULATORY COMMISSION 2I OFFICE OF INSPECTION AND ENFORCEMENT
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- INSPECTION AND ENFORCEMENT MANUAL DI CHAPTER 2515 LIGHT-WATER REACTOR INSPECTION PROGRAM - OPERATIONS PHASE 2515-01 PURPOSE To obtain sufficient information through direct observation and verifica-tion of licensee activities to ascertain (1) whether the facility is being operated safely and in compliance with regulatory requirements and (2) whether the lices ee's management control program is. effective.
2515-02 APPLICABILITY This inspection program is implemented when an operating license or fuel loading authorization is issued for a facility.
Portions of the light-water reactor inspection program for the startup phase also will be conduc-ted during the initial operation of a facility.
The light-water reactor 3
inspection program for the preoperational testing and operational prepared-J}
ness phase will have been completed or will be close to completion by the time this program is in effect.
This inspection program will remain in effect until the facility license is significantly modified to reflect a deactivated status, i.e., retired in place or decommissioned.
In either case, the licensee will be required to submit information to the Office of Nuclear Reactor Regulation (NRR) describing its plans for achieving the desired plant status.
Following approval by NRR, the licensee's application will provide the basis for the development of specific NRR inspection activities for the work required to achieve a deactivated status.
Additional inspection requirements will be developed to verify that the licensee management control program is effective for the deactivated facility (MC 2516).
2515-03 DEFINITIONS Triannually (3 yr):
The inspection effort should be performed every 3 years so that the interva'l between inspections is no less than 27 months and no greater than 45 months.
Biannually (2 yr):
The inspection effort should be performed every 2 years so that the interval between inspections is no less than 18 months and no greater than 30 months.
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11/12/86 nw q
' Annually (A):
The inspection effort should be performed every year-so =
that the interval between inspections is = no less than 9 months and no greater than 15 months, Semiannually (S):
The inspection effort should be performed two times each year so that the interval between inspections is no less than 4 months and no greater than 8 months.
Quarterly (Q):
The inspection ef fort should be performed four times each year so that the interval between inspections is no less than 2 months and no greater than 4 months.
Bimonthly (BM):
The inspection effort should be performed live times each year so that the interval between inspections is no less than 1 month and no greater than 3 months.
Monthly (M):
The inspection effort should be performed at least 12 times each year so that the interval between inspections is no less than 20 days and no greater than 40 days..
Weekly (WK):
The inspection effort should be performed at least 48 times per year so that the interval between inspections is no less than 4 days id no greater than 11 days.
Biweekly (BW):
The inspection effort should be performed at least 24 times during a 12 month period so that the interval between inspections is no less than 11 days and no greater than 18 days.
Daily (D):
The inspection effort should be performed at least three times in a normal 5-day work period.
Refueling (R):
The inspection effort should be performed each refueling.
When Required (W):
The inspection effort should be performed when the ac-tivity or event occurs at the facility as specified in the guidance section of specific inspection procedures or as specified by a note under the in-dividual inspection procedure listed in Appendix A of this chapter.
2f15-04 RESPONSIBILITIES AND AUTHORITIES 04.01 Director, Appropriate Regional Office Division.
Overall adminis-tration and implementation of the inspection program outlined in this j
chapter for licensed power reactors within regional boundaries 04.02 Chief, Project Branch (Regional Office).
Administration and imple-mentation of the inspection program outlined in this chapter for licensed power reactors assigned.
04.03 Section Chief (Regional Office).
Administration and implementation of the inspection program outlined in this chapter for licensed power reactors assigned, f
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11/12/86
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2515-05 DISCUSSION This chapter provides information for the scheduling of inspections and
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guidance regarding the implementation of the inspection program.
The program establishes uniform inspection methodology and allows sufficient flexibility to the regions for making the best use of their inspection re-sources.
Experience has shown that inspector manpower requirements needed to com-plete the inspection program in add l tion to the reactive inspection demands generally exceed the available inspection resources.
For this reason this chapter establishes a
priority system for inspection completion with highest emphasis on those matters most closely linked to operational safety verification.
This system for inspection completion should be followed except when an ongoing operational event at a plant precludes it; in which case the inspection staff should follow the event until redirected by the regional office.
The inspection program has been divided into three parts: Minimum, Basic, and Supplemental.
Appendix A defines the procedures that comprise each program part.
The Minimum Program -shall be completed at all operating nuclear facilities without exception.
In some cases (radiation controls and security), the Minimum Program is included in the Basic Program.
Regional supervisors should require the performance of selected Supplemen-tal Program inspection procedures on a basis of assessed need or problems at a facility.
Inspection resources for routine inspections should be allocated based on the latest SALP (systematic assessment of licensee performance) evaluation rating as follows:
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SALP functional areas rated Category I:
The Minimum Program shall be conducted.
Performance of the Basic or Supplemental Program is not re-quired for functional areas rated Category I.
However, areas where a negative trend has been identified are eligible for enhanced inspections as selected from the Basic Program.
If a licensee's facility is rated as Category I for two consecutive SALP periods, the Basic Program should be conducted at the site in addition to the Minimum Program during the third period.
SALP functional areas rated Category II:
The Minimum and Basic Programs shall be conducted.
Inspection effort should be modified accordingly (increased or decreased) for areas where either positive or negative trends are identified.
SALP functional areas rated Category III:
The Minimum Program shall be conducted.
Basic and Supplemental Program inspection procedures shall be implemented based on deficiencies identified in the SALP process or per-formance indicators.
Areas where significant improvements are underway and a positive trend is indicated may be considered for performance of just the Basic and Minimum Programs.
h 14
- 25'153 Issue Date:
11/12/8ti L-
For facilities that have received new operating licenses, at least the Min-imum and Basic Proorams shall be conducted until two post-licensing SALP evaluations have been completed.
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The above program implementation requirements establish a baseline routine inspection program which concentrates attention on poor performance areas while maintaining a minimum level of inspection coverage in all areas.
It is not intended that the baseline program preclude enhanced inspections in any functional area based on identified weaknesses, nor is it intended to preclude reduced inspection efforts for areas where significant improve-ments are under way and a positive trend has been identified.
For example, while a facility may have been rated as a Category II in Operations, declining performance overall or in a particular area of operations may require increased inspection attention during the current SALP evaluation period.
Similarly, a facility could have been rated as a Category III in an area where significant improvements are under way to such an extent that inspection effort may be reduced to the Basic and Minimum Programs.
To facilitate management of inspection resource allocation and tracking of inspection history, site-specific inspection plans shall be developed.
Site-specific inspection plans shall project the planned inspection activi-ties by the region for a specific site for at least the next 12 months.
The results of the latest SALP assessment will be a primary basis for determining the amount and direction of routine inspection activities planned.
However, the SALP-determined inspection activities should be tempered by other circumstances such as current issues, recent events, and trends indicated by recent inspections, including those performed by y
Headquarters.
It is expected that the plan will be a living document and be subject to adjustments as justified by some of the factors mentioned
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above.
Copies of the site specific inspection plans are to be kept on file
)
in the regional office.
When performed, Headquarters inspections will normally cover some areas included within this program.
Headquarters will issue a memorandum af ter i
completion of the inspection to document those inspection procedures for which the region may take credit for total or partial completion.
2515-06 RESIDENT INSPECTOR POLICY The resident inspectors provide the major onsite NRC presence for direct observation and verification of licensee activities.
The resident inspec-tors also are the primary onsite evaluators for the NRC inspection effort resulting from LERs (Licensee Event Reports), events, or incidents.
It is expected that the greater part of initial event-related inspection effort will be performed by the resident inspectors (who may be supplemented by other inspectors, depending on the type of event).
Regional managers will decide when normal inspection activities will be resumed by.those involved with inspecting the event.
The inspection program provides for 20 percent independent inspection for resident inspectors.
It is expected that as a direct result of the resi-dent inspectors' increased onsite time coupled with their broad facility knowledge, they will identify certain areas where independent inspection
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effort may be warranted.
l g ssue,Date:
11/12/86,
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1 This inspection program prescribes inspection activities to be performed on backshif ts or weekends each week.
Backshif t and weekend inspections will be performed by senior resident inspectors and resident inspectors.
The goal for backshift and weekend inspection activities is 20 percent of an inspector's normal work week, averaged over a year.
It is expected that this effort will include normal inspector coverage of items in the program (i.e., refueling outages, unscheduled outages) as well as those specifical-ly designated for the backshifts. There is no requirement that the inspec-tor leave the site and return on the backshif t for backshift inspection effort.
The placement of a second resident inspector at a single-unit operating site provides increased inspection effort for specific program areas beyond the effort that can be achieved by a second resident inspector at a multi-unit site.
Approximately 1000 inspection hours per year per site are available by the addition of a second resident inspector. While a signifi-cant portion of the added inspection resource will serve to enhance the l
routine inspection activities, some of this added resource should be allocated to other inspection areas.
A breakdown of how the 1000 inspec-tio6 hours should be generally allocated is described in Appendix B.
This is not intended to assign inspection responsibilities to a specific resi-4 dent inspector, but rather to indicate areas where increased inspection effort can be applied.
The additional resident inspector hours also result in a decreased inspection effort by the regional inspectors at single-unit operating sites.
The time distribution of inspection hours described in Appendix B assumes the implementation of the Basic and Minimum Programs at a site and also
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assumes that the second resident inspector is fully qualified.
Changes in either of the above assumptions should result in appropriate changes in i
inspection program assignment by regional management.
2515-07 REGIONAL INSPECTION POLICY Regionally based inspectors will conduct inspection procedures as directed by their supervisors.
Regionally based inspectors of ten will be involved in inspection activities of a more specialized nature than those inspection activities performed by the resident inspectors.
Certain aspects of their inspection activity shall be conducted in the regional office, i.e., por-tions of procedure review and administrative program inspection.
The regionally based inspector also may conduct independent inspection ac-tivities.
There is not a stated goal for regionally based inspections on backshift or for independent inspection.
However, backshift inspection will be performed whenever required to complete the inspection.
l The senior resident inspector must be kept apprised of regionally based in-l spector activities at the facility.
The appropriate section chief shall ensure coordination of regional inspection activities and keep the senior l
resident inspector informed.
Regionally based inspectors should contact the senior resident inspector before the inspection to obtain information concerning the availability of specific licensee personnel and the status of plant conditions that may affect the planned inspection.
In addition, regionally based inspectors h4
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shall make contact with the senior resident inspector as soon as is conve-
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nient after their arrival at the site to ensure a coordinated NRC presence at the facility.
They should advise the senior resident inspectors of changes to their planned inspection effort and schedule for the licensee
.)
exit interview.
The senior resident inspector will inform the regionally based inspectors of any unique activities in progress and will offer specific inspection suggestions.
The regionally based inspectors should brief the senior resident inspector about the results of their inspection before the exit interview with licensee management.
The senior resident inspector should attend all exit meetings where significant enforcement action or other significant unresolved issues are expected to be discussed.
2515-08 TEAM INSPECTIONS R
The team inspection effort has become a part of nearly every aspect of li-R censee evaluation.
The advantages of this type of inspection are largely R self-evident.
The collective insight of an inspection team regarding tech-R nical and regulatory issues provides a broader perspective of underlying R problems associated with the findings of each individual inspector. Team R inspections provide an in-depth and balanced assessment of licensee perfor-R mance allowing parallels and conclusions to be drawn from among the issues R in different functional areas.
Team inspections allow a greater degree of R i n-the-field supervision and in this regard are particularly useful for R training and supervising less experienced inspectors.
R The Safety System Functional Inspection (SSFI) is a type of team inspection R g
that has proven to be effective in identifying problems that can degrade R the operational readiness of safety systems.
Many of the problems that R T
have been identified by this inspection process would likely have gone un-R j
3 detected despite aggressive implementation of the routine inspection pro-R i
gram..The SSFI methodology is outlined in Appendix C.
R SSFIs will continue to be implemented by headquarters personnel with the R assistance of regional inspectors.
Regional implementation is on a volun-R i
tary basis.
R 2515-09 GENERAL GUIDANCE The inspection program described in Appendix A is intended to provide the framework for managing inspection resources without being totally prescrip-tive.
The program allows variations in manpower availability to be accommodated by a specified corresponding program level of effort.
Flexi-bility in meeting inspection objectives is thus prescribed by prioritizing the program in accordance with importance to safety.
At the same time, a minimum level of effort at a facility is specified, below which inspection must not decrease.
It is intended to place inspection emphasis on elements of licensee activities most important to safety and to recognize licensee performance in the efficient use of inspection resources.
- Further, it is expected that resident inspectors will perform those l
inspections that emphasize observations of plant operations in progress and field verification of licensee activities, e.g.,
observation of testing or verification of safety-related system lineup.
These procedures are designed to effectively employ the resident inspector's site-specific knowledge for assessing the adequacy of licensed activities.
j 1
y iIs' sue, Date:.o 11/12/86j
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Although each inspection procedure contains many line items, these items are provided as guidance and the individual inspector is expected to apply a professional judgment regarding the need for completing each specific item.
For example, an inspector may have assurance that the requirement has been satisfied via some other source, i.e., LER followup, independent inspection effort, temporary instruction followup.
In such cases, the inspector should not perform these specific items.
In summary, the line items in Section II of inspection procedures list the attributes which should be considered when evaluating the area covered by the inspection procedure.
In addition, situations will arise where the specified fraquen-cy cannot always be met for completing inspection procedures in the Basic Program.
These situations should be reviewed and the revised frequency accepted by the responsible regional Division Director wi th the under-standing that, in general, the desired position is that the Basic Program is to be completed across the regions.
As stated in 10 CFR and elsewhere in this manual (MC 2500), NRC inspectors perform a basic mission in determining that a licensee meets current regulatory requirements and commitments.
Identifying specific instances where a licensee fails to meet such requirements and commitments, although important, has frequently in the past resulted in correction of symptoms rather than correction of underlying causes of licensee problems.
Because of limited number of inspectors, the NRC inspection program covers only very small samples of licensee activities in an area.
Thus, it is impor-tant that an inspector evaluate whether a noted noncompliance or deficiency represents an isolated case or may signify a broader, more serious problem in that area.
To provide the perspective to perform this evaluation, the inspector should:
3j a.
Keep currently informed of deficiencies, audit findings, and plant problems identified by the licensee's organization, b.
Ascertain whether additional personal inspection effort is merited in the area under consideration.
Where the evidence indicates that a problem may exist, enforcement action should be employed to require the licensee to demonstrate to the NRC that it has not lost control of that area.
Regional supervision should be consulted whenever such enforcement action appears appropriate to the individual inspector.
END Appendices 2515 Issue Date:
11/12/86
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APPENDIX A A.
PURPOSE To' describe the Minimum, Basic, and Supplemental Programs.
B.
REQUIREMENTS Pro' ram:
g Inspection Functional Area:
Inspection Procedure No.
Inspection Procedure
Title:
Frequency 7
Minimum:
Plant Operations:
71707 Operational Safety Verification D/WK/BWK 71710 ESF System Walkdown BM d'
'/
92709 Licensee Plans for toping with Strikes W
. (every 3 years and before impending strikes) 92710 Licensee's Inittel Implementation of Strike Plans W
(at plant turnover to nonstriking personnel) 92711 Continued Implementation of Strike Plans During W
Extended Strike (weekly for the duration of the strike) 92712 Resumption of Normal Operation After Strike W
(during plant turnover to returning plant personael) 93702 Onsite Followup of Events at Operating Power W
Reactors T
Basic:
71714 Cold Weather Preparations W
Supplemental:
42700 Plant Procedures W
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??S15 A-1 Issue Date:
07/14/86
Program:
Inspection Functional Area:
Inspection
]
Procedure No.
Inspection Procedure Title Frequency
/
71715 Sustained Control Room and Plant Observation W
86700 Spent Fuel Pool Activities W
Minimum:
Radiation Controls:
83000 Radiation Protection A
Series 84000 Radioactive Waste Management A
Series Basic:
79701 LWR Water Chemistry Control and Chemical Analysis A
i 80721 Radiological Environmental Monitoring 2 yr 83722 Radiation Protection, Plant Chemistry, and A
Radwaste:
Organization and Management Controls 83723 Radiation Protection, Plant Chemistry Radwaste, A
and Transportation:
Training and Qualifications 83724 External Occupational Exposure Control and A
Personal Dosimetry 83725 Internal Exposure Control and Assessment A
83726 Control of Radioactive Materials and A
Contamination, Survey, and Monitoring 83727 Facilities and Equipment A
83728 Maintaining Occupational Exposures ALARA A
j 83729 Occupational Exposure During Extended Outages W
84722 Solid Wostes A
84723 Liquids and Liquid Wastes A
f 64724 Gaseous Waste System A
i 84725 Quality Assurance and Confirmatory Measurements A
l for In-Plant Radiological Analysis i
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- (Issue;c:te:
07/14/86;
,A-2 2515 0.
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Program:
Inspection.
Functional Area:
Inspection t
Procedure No.
Inspection Procedure Title Frequency 86721 Transportation A
Supplemental:
79501 LWR Water Chemistry Control and Chemical Analysis W
79502 Plant Systems Affecting Plant Water Chemistry W
80521 Radiological Environmental Monitoring W
W 83522 Radiation Protection, Plant Chemistry, Radwaste,.
and Environmental:
Organization and Measurement Controls 83523 Radiation Protection, Plant Chemistry, Radwaste, W
Transportation and Environmental:
Training and Qualifications 83524 External'5ccupationalExposureControland W
Personal Dosimetry 83525 Internal Exposure Control and Assessment W
83526 Control of Radioactive Materials and W
Contamination, Surveys and Monitoring 83527 Facilities and Equipment W
84522 Solid Wastes W
84523 Liquids and Liquid Wastes W
84524 Gaseous Waste System W
84525 Quality Assurance and Confirmatory Measurements W
for In-Plant Radiochemical Analysis l
84850 Radioactive Waste Management - Inspection of W
{
Waste Generator Requirements of 10 CFR 20 l
and 10 CFR 61 l
86740 Inspection of Transportation Activities W
Minimum:
Maintenance:
62703 Monthly Maintenance Observations M
2515 A-3 Issue Date:
07/14/86
Program:
Inspection Functional Area:
Inspection Procedure No.
Inspection Procedure Title Frequency Basic:
62700 Maintenance Program Implementation 2 yr Supplemental:
W 62702 Maintenance Program 62704 Instrument Maintenance W
62705 Electrical Maintenance W
Minimum:
Surveillance:
61707 Determination of Reactor Shutdown Margin W
(performed in Minimum Program following detection of inoperable control rod) 61726 Monthly Surveillance Observation M
Basic:
61725 Surveillance Testing and Calibration Control 3 yr Program
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l Supplemental:
61700 Surveillance Procedures and Records W
W 61701 Complex Surveillance (one major surveillance each refueling outage) 61702 Surveillance of Core Power Distribution Limits W
61705 Incore/Excore Detector Calibration W
61706 Core Thermal Power Evaluation W
61707 Determination of Reactor Shutdown Margin W
61708 Isothermal Temperature Coefficient of Reactivity W
j Measurement 61709 Power Coefficient of Reactivity W
j 1
61710 Control Rod Worth Measurement W
i
- Performed in the Minimum Program under IP 72700 for every refueling.
j Issue Date:
07/14/86 A-4 2515 l
4 Program:
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Inspection Functional-Area:.
Inspection Procedure No.
Inspection Procedure Title Frequency 61728 Independent Measurement of RCS Leak Rates For W
a PWR
-Basic:
Fire Protection:
64704
-Fire Protection / Prevention Implementation A
Minimum:
Emergency Preparedness:
82301 Evaluation of Exercises for Power Reactors A.
82701' Operational Status of the Emergency Preparedness A
R Program Basic:
82102 Status of Late Preoperational Phase Emergency W
R Preparedness Programs 82201 Emergency Detection and Classification A
82202 Protective Action Decision Making A
}
82203 t; notifications and Communications A
82204-Changes to the Emergency Preparedness Program A
l 82205 Shift Staffing and Augmentation A
82206 Knowledge and Performance of Duties (Training)
A 82207 Dose Calculations and Assessment 3 yr 82209 Public Information Program 3 yr 82210 Licensee Audits A
Supplemental:
A TI 2513/55 Emergency Preparedness Implementation Appraisal W
Program 1
- 0nly perform appropriate sections.
2515 A-5 Issue Date:
07/14/86
4 Program:
Inspection Inspection functional Area:
Procedure No.
Inspection Procedure Title Frequency
' Minimum:
Security:
A 81000 Physical Security Series n
, Basic:
81018 Security Plan and Implementing Procedures A
81020 Management Effectiveness - Security Programs A
A 81022 Security Organization A
81034 Security Program Audit A
80138 Records and Reports A
81042 Testing and Maintenance A
81046 Locks, Keys, and Combinations A
81052 Physical Barriers-Protected Areas 81054 Physical Barriers-Vital Areas, Material Access A
)
Areas and Controlled Access Areas A
81058 Security System Power Supply A
81062 Lighting A
81064 Compensatory Measures 81066 Assessment Aids A
81070 Access Control - Personnel A
i 81072 Access Control (Power Reactor) - Packages A
81074 Access Control - Vehicles A
{
- Regions have the prerogative to determine that any inspection program f
requirements have been fulfilled by Regulatory Effectiveness Reviews (RERs).
Such credit should depend on the accompanying inspector's judgment and the conduct of the RER within 6 months of a scheduled inspection.
)
Issue Date:
07/14/86 A-6 2515 1
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' Program:
. Inspection-Functional Area:
Inspection
' Procedure No.
Inspection Procedure Title Frequency 81078 Detection Aids - Protected Areas A
81080
' Detection Aids - VA, MAA, CAA A
81084 Alarm Stations A
81088 Communications A
81401 Plans Procedures and Reviews W
81403 Receipt of New Fuel at Reactor Facilities W
A 81431 Fixed 51te Physical Protection of LSNM W
81501 Personnel Training and Qualifications - General A
Requirernents 81601 Safeguards Contingency Plan Implementation Review A
81810 Physical Protection Safeguards Information 2 yr 85102 Material Control and Accounting - Reactors 3 yr
..) Supplemental:
81000 Physcial Security W
Series 85102 Material Control and Accounting - Reactors W
-Minimum:
Outages:
61720 Containment Local Leak Rate Testing 2 yr R
70313 Containment Integrated Leak Rate Test W
R Surveillance (performance for each CILRT) 72700 Startup Testing - Refueling R
R 73753 Inservice Inspection - Observation of Work and W
Work Activities (conduct for PSI, first ISI, thereafter, each outage in w',ich significant ISI, Code repair / replacement is performed)
- To be performed when new fuel arrives on site.
- Increased sample size is required by each IP when performitig this inspec-tion under the Supplemental Program.
2515 A-7 Issue Date:
07/14/86
i i
Program:
Inspection-Functional Area:
Inspection i
Procedure No.
Inspection Procedure Title Basic:
37700 Design, Design Changes and Modifications A
70307 Containment Integrated Leak Rate Test Review W
R (performed prior to each CILRT)-
70323 Containment Leak Rate Test Results W
R Evaluation (performed following each CILRT) 71711 Plant Startup from Refueling R
a 72701-Modification Testing W
73051 Inservice Inspection - Review of Program W
(conduct for PSI, first ISI, thereafter, every other outage for program revisions only and for 10 year program submittal to NRC) 73052 Inservice Inspection - Review of Procedures W
(conduct for PSI, first ISI, thereafter, each outage, keying only on procedure revisions) 73755 Inservice Inspection - Data Review and Evaluation W
[ conduct for first ISI, thereafter, twice in a 3 outage cycle (one in-office, one onsite review)]
Supplemental:
37701 Facility Modifications W
55050 Nuclear Welding General Inspection Procedure W
55100 Structural Welding General Inspection Procedure W
55150 Weld Verification Checklist W
'l-56700 Calibration W
(performed each refueling) 57050 Nondestructive Examination Procedure Visual W
Examination Procedure Review / Work Observation /
Record Review 57060 Nondestructive Examination Procedure Liquid W
Penetrant Examination Procedure Review / Work Observation / Record Review
)
Issue Date:
07/14/86 A-8 2515
Program:
i Inspection Functional Area:
Inspection Procedure No.
Inspection Procedure Title Frequency 1
l l
57070 Nondestructive Examination Procedure Magnetic W
Particle Examination Procedure Review / Work Observation / Record Review 57080 Nondestructive Examination Procedure Ultrasonic W
Examination Procedure Review / Work Observation /
Record Review 57090
' Nondestructive Examination Procedure Radiographic W
Examination Procedure Review / Work Observation /
Record Review.
60705 Preparation for Refueling W
(prior to first refueling, prior to refueling if SALP 3) 60710 Refueling Activities W
(prior to.first refueling, prior to refueling if SALP 3) 70370 Testing Piping Support and Restraint Systems W
(performed each refueling)
)
Minimum:
Quality Programs and Administrative Controls Affecting Quality:
35701 QA Program. Annual Review A
92703 IE Bulletin, Confirmatory Action Letter, and W
Generic Letter Followup Basic:
36100 10 CFR Part 21 Inspections W
40700 Onsite Review Committee W
40701 Offsite Review Committee W
90712 In-Office Review of Written Reports of W
Nonroutine Events at Power Reactor Facilities 92700 Onsite Followup of Written Reports of W
Nonroutine Events at Power Reactor Facilities 92701 Followup (Note:
followup of IE information W
notices and IE bulletins sent for information shall be performed annually.)
2515 A-9 Issue Date:
07/14/86
l 1
(
Program:
l Inspection Functional Area:
Inspection
)
i i
Procedure No.
Inspection Procedure Title Frequency 92702 Followup Items of Noncompliance and Deviations W
92720 Corrective Action 2 yr R
1 Supplemental:
l 35750 QA Program Measuring and Test Equipment W
R (performed each refueling) l 36700 Organization and Administration W
l 37702 Design Change and Modifications Program W
R 37703 Test and Experiments Program W
38701 Procurement Program W
38702 Receipt, Storage, and Handling of Equipment W
and Materials Program 39701 Records Program W
39702 Document Control Program W
]
40702 Audit Program W
40703 Offsite Support Staff W
40704 Implementation - Audit Program W
50095 Spent Fuel Storage Racks W
65051 Low Level Radioactive Waste Storage Facilities W
90713 In-Office Review of Periodic and Special Reports W
(when receive periodic /special report addressed to region / Headquarters) 90714 Nonroutine Reporting Program W
Supplemental:
Licensing Activities:
94702 Participation in NRR/ Licensee Meetings W
(performed for each meeting attended) uPerformed in Minimum Program under IP 35701 Issue Date:
07/14/86 A-10 2515
Program:
Inspection Functional Area:
Inspection
)
Procedure No.
Inspection Procedure Title Frequency 1
Minimum:
Training and Qualification Effectiveness:
n 41400 Nonlicensed Staff Training A
A 41701 Licensed Operator Training A
Minimum:
Inspector Meetings:
30703 Management Meetings Entrance and Exit W
Interviews (all management meetings unrelated to SALP or item followup, as discussed in IPs 92700, 92701, 92702, and 92703)
Basic:
30702 Management Meetings (as needed)
W Supplemental:
94600 Information Meetings with Local Officials W
(performed for each meeting)
)
94703 Media Contacts W
(performed for each meeting attended)
- Has inspection requirements cutting across several functional areas.
END l
4
)
2515 A-11 Issue Date:
07/14/86 j
APPENDIX.8
.)
A.
PURPOSE.
To describe the distribution of the 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of inspection effort made available by-the. addition of a second resident inspector.
This increased inspection effort is not intended to be accomplished exclusively by the
'second resident inspector nor is it to be considered a breakdown of the second resident's - time.
This distribution is an indication of where the increased inspection effort available at a single-unit operating site
.should be' applied.
B..
GUIDANCE Inspection Hours Area 200 Plant Operation; i.e., Control Room and Plant Tours (IPs 71707.and 71710) 100 Maintenance (IPs 62703, 62704, and 62705) 100 Surveillance (IP 61707)
.}
90 Radiation Protection (IP 71707; 80 Safeguards (IP 71707) 80 Emergency Preparedness (IP 82301) 350 Other.(support to inspections at other sites, event followup, additional inspection of poor performance areas, equipment qualification, etc.)
I END
)
2515 B-1 Issue Date:
07/15/86
i APPENDIX C SAFETY SYSTEM FUNCTIONAL INSPECTION 1.
INSPECTION OBJECTIVE A.
The objective of a Safety System Functional Inspection (SSFI) is to assess the operational readiness of selected safety systems by determining whether:
1.
The systems are capable of performing the safety functions required by their design bases.
2.
Testing _- is adequate to demonstrate that the systems would perform all of the safety functions required.
3.
System maintenance (with emphasis on pumps and valves) is adequate to ensure system operability under postulated ac-cident conditions.
4.
Operator and maintenance technician training is adequate to
)
ensure proper operations and maintenance of the system.
5.
Human f actors considerations relating to the selected sys-tems (e.g., accessibility and labelling of valves) and the supporting procedures for those systems are adequate to en-sure proper system operation under normal and accident con-ditions.
6.
Management controls including procedures are adequate to ensure that the safety systems will fulfill the safety functions required by their design bases.
II.
INSPECTION METHODOLOGY A.
Review the design-basis requirements for the selected system (s) and determine the operating conditions under which each active component will function during accident or abnormal conditions.
l This review should determine if the design basis is met by the installed, tested component and if the design basis is the correct one.
1.
For valves: What permissive interlocks are involved? What differential pressures will exist when the valve strokes?
Will the valve be repositioned during the course of the event?
What is the source of control / indication power?
Issue Date:
11/12/86 t
i What control logic is involved?
What manual actions are required to backup and restore a degraded function?
2.
For pumps:
What are the flow paths the pump will experi-ence during accident scenarios?
Do the flow paths change?
What permissive interlock / control logic apply?
How is the nump controlled during accident conditions?
What manual actions are required to back up and restore a degraded function? What suction / discharge pressures can the pump be expected to experience during accident conditions? What is the motive power for the pump during all conditions?
3.
For instrumentation and sensors: What plant parameters are used as inputs to the initiation and control systems?
Is operator intervention required in certain scenarios?
Are the range and accuracy of instrumentation adequate? What is the extent of surveillance and/or calibration of such instrumentation?
B.
Review the design of the selected system (s) as installed in the plant.
1.
Determine if the as-built design and installation matches the current design / licensing basis requirements for that particular facility.
For example, are fuses and thermal overloads properly sized; are current dc loads within the l
capacity of the station batteries; and is the instruments-q tion adequate in range and accessibility for operations to control the system under normal and abnormal conditions?
f
-)
2.
Determine if system modifications implemented since initial 1icensing have introduced any unreviewed safety questions.
For example, have modified structures surrounding safety-related equipment, components, or structures been evaluated for seismic 2-over-1 considerations, and have modified equipment components falling under the scope of 10 CFR 50.49 been thoroughly evaluated for environmental equipment qualification considerations such as temperature, radia-tion, humidity?
3.
Evaluate the licensee's drawing control
- program, the control and use of design input information, and the adequacy of design calculations from the perspective of modifications made to the selected safety system.
C.
Review the maintenance and test records for the selected system (s).
1.
Determine if the system components have been adequately tested to demonstrate that they can perform their safety function under all conditions they might experience in an accident situation.
Determination of adequate testing may require consideration of removing all actuator power, including both electrical and pneumatic, for fail-safe valves (see IE Information Notice No. 85-84, " Inadequate In-service Testing of Main Steam Isolation Valves").
Issue Date:
11/12/86 C-2 2515
-2.
Determine ~ if the system components are being adequately
~
maintained to ensure their operability under all* accident conditions.
For example, are limit and torque switch set-
' tings proper; is the instrument air system adequately
.)
maintained to ensure the reliability of pneumatic valves; are fuse and thermal overload sizes correct; and are pipe
- supports, seismic restraints and shielding being main-tained?
3.
Determine the adequacy of the licensee's preventive main-tenance program for the system.
As a part of this assessment, refer to the appropriate vendor ' technical manuals.
4.
Support system and plant modifications should be evaluated to the extent possible to ensure that' system design capabi-lity as demonstrated by preoperational. testing has not been compromised.
For instance, the addition of a fire' barrier in an ECCS pump room may compromise room cooling capabili-ties by altering air flow paths.
D.
Perform walkdown of selected systems.
1.
Determine if ccmponents are labeled 'and accessible.
For example, can the components be operated locally / manually if required by the licensing basis, and is there HP/ security interference?
2.
Determine if MOV operators and check valves (particularly lift-type) are installed in the orientation required by the
)
manufacturer.
Additionally, a human factors assessment of component orientation (such as the direction of handwheel rotation for valves installed upside down) should be made.
3.
Determine if system lineup is consistent with design /licen-sing basis requirements.
This lineup inspection should i
include considerations of the normal and backup power supplies, control circuitry, indication and annunciation status, and sensing lines for instrumentation.
E.
Review abnormal, emergency, and normal operating procedures; maintenance procedures; and surveillance procedures for the selected system (s).
1.
Assess the technical adequacy of the procedures.
2.
Determine if the procedural steps will achieve required system performance. for normal, abnormal, and emergency conditions.
This should include consideration of operator actions to compensate for shortcomings in design.
3.
Determine if operations and maintenance personnel receive 1
adequate training pertaining to the selected system (s) and i the degree of training provided is consistent with the amount of technical detail included 'in procedures.
In particular, -verify that operators are trained on system 2515 C-3 Issue Date:
11/12/86 i
response, f ailure modes, and required actions involved in' all credible scenarios in which the system is required to function.
4.
Determine if surveillance test procedures comprehensively I
l address required system responses.
For example, does the I
tested lineup duplicate the accident response lineup; are check valves tested to prevent reverse flow; and does the l
test establish any artificial initial conditions?
F.
Review the operational experience of the selected system (s).
This would include LERs, NPRDS,10 CFR 50.72 reports, enforce-ment actions, nonconformance reports, and maintenance work requests.
1.
Determine the historical reliability of the system and its components based on the review and analysis of the opera-tional experience.
2.
Determine if the licensee has aggressively pursued, identified, and corrected root causes of failures.
3.
Determine the extent of the maintenance backlog and ascer-tain if the licensee has a program to identify, prioritize and perform timely safety-related maintenance activities.
Is thcre a 'oacklog of safety-related maintenance?
III.
INSPECTION GUIDANCE A.
Plant Specific Probabilistic Risk Assessment should be reviewed
)
i as part of the system selection methodology, if available.
Studies conducted by AE0D also can provide useful data for determining which system to select.
B.
Past experience with SSFls has demonstrated that identifying the detailed design-basis requirements for the selected safety systems can be quite difficult and time consuming for the inspection team as well as for the licensee.
The difficulty in clearly identifying design-basis requirements at older plants is related to the fact that the information often has never been assembled before and is typically scattered among the records stored at the plant, at the licensee's cor) orate offices,ffices.
at the and at the 15$$ vendor's o architect engineer's offices'ld be made to provide the licensee Consequently, an effort shou with adecuate advanced notice regarding the safety systems to be inspectec to allow the licensee time to begin collecting the needed documentation.
The inspector should compare the original 4
FSAR system design descri) tion to that contained in the USAR as i
part of the effort to icentify detailed design-basis require-i ments.
C.
The design review portion of the inspection should be performed by inspectors with extensive nuclear plant design experience,
)
preferably comparable to the experience gained through, previous employment with an architect engineering firm.
It is important also that the inspectors performing the design review have a
)
Issue Date:
11/12/86 C-4 2515 l
'e i-good understanding of. integrated plant operations, maintenance, testing,. and qual.ity assurance so that they-are able to relate their findings to the other functional areas being inspected.
I D.
When performing the review of maintenance and test records, it is essential for the inspector to' focus'on the technical details of ' how the activities were performed.
For example, were the closing limit switches set.with the motor-operated valve fully shut. or.four turns off the shut. seat?- The review of test-records should go beyond a review of the in-service testing and surveillance programs for Technical Specifications.
The inspector.should seek the. answer to the fundamental question of whether or not the safety systems and all included components have been tested to demonstrate that they will perform their intended safety functions as defined in the design basis.
E.
As part of the system walkdown, the inspector should analyze the adequacy of the system lineup, accessibility, indications,
_ relative to the most limiting design-basis conditions (e.g.,
degraded power and lighting, single failure, loss of non-safety-related indications, and harsh environments).
F.
As was the case for the review of maintenance and test records (discussed'in III.C), it is essential for,the inspector to focus on. the technical details of the operating, maintenance, and surveillance procedures reviewed.
The inspector should verify that the emergency and abnormal operating procedures are ade-quate to handle the most limiting design-basis events. Where it is not reasonable for procedures to provide' detailed guidance, j
the inspector should verify that the licensee's training program
/
ensures that the operators are knowledgeable in the areas of concern.
G.
The effectiveness of the SSFI methodology is greatly enhanced if
'the various inspection team members are able to benefit from each other's inspection efforts.
Accordingly, frequent, even daily, team meetings are encouraged to allow the team members to share their' findings.
It has been the experience of the head-quarters-based SSFI effort that many of the more significant findings originate' from team meeting discussions that allow related inspection findings in different functional areas to be pieced together.
IV.
INSPECTION APPROACH A.
Team Composition
' An inspector should be assigned to each of the following areas:
electrical design, mechanical design, maintenance, surveillance and testing, operations, and training.
The detailed. system walkdown can be done by an additional inspector participating for 'only part of the onsite activities, or this aspect can be covered by the operations inspector.
A full-time team leader without any specific area assignments should have the primary responsibility to provide guidance and 2515 C-5 Issue Date:
11/12/86
Fs coordinate team activities.
It is recommended that the team' leader have several years of inspection experience, lhe senior resident inspector for the site being inspected should not be i
assigned as a participating team member; however, his/her i
involvement in the inspection process should be encouraged to the extent his/her resident duties will allow.
B.
Schedule of Inspection Activities The following is a recommended schedule of inspection activi-ties:
Week 1.
The mechanical and electrical inspectors start inspec-tion of design activities focusin-g on recent design changes of the selected safety system.
These activi-1 ties should be conducted at the licensee's engineering offices.
Week 2.
The inspection team starts their onsite activities.
Week 3.
No onsite or engineering office inspection activities are conducted.
The licensee has time to produce requested design information.
The inspection team can brief management and review the issues in-office.
Week 4.
Inspection team is back on-site.
The exit meeting usually is held Friday morning.
A pre-exit meeting and rehearsal of inspector presentations is conducted late Thursday af ternoon with the participation of NRC management representatives.
At least 2 weeks prior notification should be provided to the i
licensee before the inspection begins.
The licensee should be told which safety system (s) will be inspected.
At least 1 week of preparation time should be allowed for the inspection team members before beginning their onsite activities, and the team should establish contact with licensee systems engineers when the team arrives on-site.
C.
Credit for Inspection Activities Inspection credit input should be made to the 766 data base for the appropriate inspection procedures of IE MC 2515.
Poten-tially appropriate inspection procedures include:
35701 - QA Program Annual Review 37700 - Design, Design Changes and Modifications J
37701 - Facility Modifications j
37702 - Design Changes and Modifications Program 41701 - Licensed Operator Training 42700 - Plant Procedures 61700 - Surveillance Procedures and Records 61725 - Surveillance Testing and Calibration Control Program 61726 - Monthly Surveillance Observations i
Issue Date:
11/12/86 C-6 2515
62702 - Maintenance Program 62703 - Monthly Maintenance Observations 62704 - Instrumentation Maintenance (Components and Systems)
Observation of Work, Work Activities, and Review of Quality Records 62705 - Electrical Maintenance (Components and Systems) Observa-tion of Work, Work Activities, and Review of Quality Records 71707 - Operational Safety Verification 71710 - ESF System Walk Down 72701 - Modification Testing 73051 - Inservice Inspection - Review of Program 73755 - Inservice Inspection - Data Review and Evaluation END i
)
l l
i l
l 1
1 2515 C-7 Issue Date:
11/12/86
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NRCVISli PNPSSECURITYPROGRAM AGENDA JANUARY 13 1.
Welcome and Briefing
\\
2.
Site Tour l
JANUARY 14 WORKINGLEVELDISCUSSIONS 1
- Security Program Information
- System Maintenance Activities l
- Modification Effort
- Schedule of Security Activities January 15 1.
Working level Discussions (Carried over from previous day) 2.
Exit Briefing
~
NRCVISIT PHYSICALSECURITY POINI OF CONTACT AREA POINT OF CONTACT NRC Visit Co-ordinator/ Licensing J. Keyes X8942 Braintree Support X8437 PNPS Overall Security Activities C. Higgins X8156 PNPS Security Maintenance R. Sherry X8215 PNPS Engineering Support R. Andrew x8823 Braintree D. Bryant X8802 Braintree
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January 8, 1987 EDISON APPOINTS RALPH G. BIRD SENIOR VICE PRESIDENT
-Boston Edison Company has named a former U.S. Navy Deputy Chief of Naval Material for Logistics and Fleet Operations to head the electric utility's nuclear organ 13ation.
Rear Admiral Ralph G. Bird, U.S. Navy (Retired), a 28-year veteran of the nuclear navy and most recently, a consultant to the nuclear power industry, has been appointed Senior Vice President-Nuclear and will report directly to
. Stephen J. Sweeney, Boston Edison's Chairman, President and Chief Executive Officer.
A. Lee.0xsen, Vice President of Nuclear Operations, and J. Edward Howard, Vice President of Nuclear Engineering and Quality Assurance, will report directly to Bird.
Since his retirement from the Navy in 1984, Bird has, served as a consultantLto several nuclear power utilities and worked for Westinghouse Electric Corporation.
Boston Edison Executive Vice President and Chief Operating Officer James M.
Lydon, who has overseen the nuclear organization since July 1, 1986, said,
" Ralph Bird brings to us leadership qualities and nuclear experience that'is 9
consistent with our stated goals of excellence." Lydon also said, "It is important to note that there will continue to be no. layers of management between the nuclear organization and the Board of Directors.
This demonstrates the on-going executive involvement at the highest levels of the company."
- _ _ _ = _ _ - _ _ _ _ _ _ _.
a#
. During his naval career, Bird served 20 years in the naval nuclear power program including extensive service in nuclear subearines.
He has also held the positions of Senior Member of the U.S. Pacific Fleet Nuclear Propulsion Examining Board; Chief of Staff, U.S. Pacific Submarine Force and Deputy Chief-of Staff for Logistics and Security Assistance for the U.S. Pacific Command.
Bird is a graduate of the U.S. Naval Academy and holds a Masters Degree in Computer Systems Management from the Naval Post Graduate School in Monterey, California.
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M BOSTON EDISON COMPANY Nuclear Org_anization Key Personnel-Telephone No.
J. M. Lydon, Chief Operating Officer E49-8902 J. E. Howard - V.P. Nuclear Engineering & QA 849-8900 A. L 0xsen - V.P. Nuclear Operations PNPS 8022 K. P. Roberts - Director of Outage Management PNPS 8189 A. E. Pedersen - Station Manager PNPS 8100 l
R. N. Swanson - NED Manager 849-8800 I
R. V. Fairbank - Licensing and Analysis Section Head 849-8804 C. H. Minott - Design Section Head 849-8803 R. E. Grazio - Site Engineering Section Head PNPS 8435 l
E. J. Ziemianski - Management Services Section Head PivPS 8111 N. 8rosee - Maintenance Section Head PNPS 8322 T. Sowdon - Radiological Section Head PNPS 8116 J. Seery - Technical Section Head PNPS 8289 i
%su______-._____-.______
e.
Form NRC-489 U. S. NUCLEAR REGULATORY COMMISSION
^
NRC MANUAL
. TRANSMITTAL NOTICE CHAPIER !aC-0516 SYSTEMATIC ASSESEC OF LICENSEE FERFOR4ANCE SUPERSEDEDs TRANSMITTED:
Number Date Number Date 0500- 17 TN lac-0516 7/25/86 18C-0516 6/12/85 Chapter
' Chapter Page Page 7/25/86 lac-0516 6/12/85 Appendix NRC-0516 Appendix REMARKS:
'Ihin revision of Chapter and Appendix 0516 includes the following major cha:Ees:
1.
Deletion of the requirement to address trend for each functional area.
Tnis revision provides for the SALP Board to include an appraisal of the licensee's performance trend in a-functional area when toth a definite trend of perfonnance is discernible to the Board and the Boani believes that continuation of the trend may result in a change of perfomance level.
2.
Addition of Trairdng ard Qualification Effectiveness as a regular functional area rather than as a temporary functional area.
3 Revision of the Fire Protection and Quality Programs and Administrative Controls Affecting Quality fanctional areas to delete the option for addressing these functional areas as a separate evaluation criterion fcr all appropriate functions.
i
)
>b 1
SYST EMATIC ASSESSMENT OF l
LICENSEE PERFORMANCE NRC Appendix 0516
(.
l CONTENTS Page PART 1 GENERAL...
1 PART 11 EVALUATION CRITERIA.
5 PART III SALP BOARD ASSESSMENT..
31 PART IV MEETING WITH LICENSEE.
15 PART V ISSUANCE OF REPORT.
17 PART VI APPENDlX TO THE SALP REPORT...
19 PART Vll -
SALP REPORT FORMAT AND CONTENT...
21 1
FIGURES FIGURE 1 -
SALP EVALUATION PROCESS.
3 TABLES 1
Page TABLE 1 Evaluation Criteria With Attributes for Assessment of Licensee Performance.
7 TABLE 2 Evaluation Matrix for Operating Phase Functional Areas.
13 TABLE 3 Evaluation Matrix for Construction l
Phase Functional Areas........
14 EXHIBITS EXHIBIT 1 -
Samples of Overall Safety Performance Characterizations..
23 EXHIBIT 2 -
SALP Board Report.
24 32 EXHIBIT 3 -
An Errata Sheet.,
33 EXHIBIT 4 -
Original Page.
EXHIBIT 5 -
Corrected Page.
34 i
Approved :
July 25, 1986 I
l l
D
~
U.S. NUCLEAR REGULATORY COMMISSION l
NRC MANUAL Volume:
0000 -General Administration Part :
0500 Health and Safety IE 1
CHAPTER 0516 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 0516-01 COVERAGE This chapter and its appendix describe the basic structure and overall procedures for implementation of the NRC program to assess licensee performance.
This program applies to all power reactors with operating licenses or construction permits (hereinafter referred to as licensees).
0516-02 OBJECTIVES 021 To improve the NRC regulatory program.
022 To permit sound decisions regarding NRC resource allocations.
023 To improve licensee performance.
024 To collect available observations on a periodic basis and evaluate licensee performance based on those observations, through the Systematic Assessment of Licensee Performance (SALP), an integrated NRC staff effort.
Positive and negative attributes of licensee performance are considered.
Emphasis is placed upon understanding the reasons for a
licensee's performance in important functional areas, and sharing this understanding with the licensee.
The SALP process is oriented toward furthering NRC's understanding of the manner in which:
(a) licensee management directs, guides, and provides resources for assuring plant safety; and (b) such resources are used and applied.
The integrated SALP assessment is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management.
0516-03 RESPONSIBILITIES AND AUTHORITIES 031 The Executive Director for Operations (EDO) provides oversight for the activities described herein.
032 The Director, Office of inspection and Enforcement (IE):
a.
implements the requirements of this chapter within the Office of Inspection and Enforcement.
b.
monitors the SALP process; evaluates and develops SALP policy, criteria, and methodology; and assesses the uniformity and adequacy of the Regions' implementation of the program.
Approved:
July 25,1986
SYSTEMATIC ASSESSMENT OF N R C -0516-033 LICENSEE PERFORMANCE l
033 The Directors, Offices of Nuclear Reactor Regulation (NRR), Analy-sis and Evaluation of Operational Data ( AEOD), and Nuclear Materials Safety and Saf eguards (NMSS), implement the requirements of this chapter within I
their Of fices.
034 Regional Administrators; a.
implement the requirements of this chapter within the Regione b,
ensure that assessments of licensee nuclear safety performance are conducted.
c.
determine when a meeting with the licensee is necessary to assure mutual understanding of the issues discussed in the SALP Board report.
d.
evaluate the SALP Board report and the licensee's comments; provide a characterization of overall safety performance; formally issue the NRC SALP report; follow up on licensee commitments; and reallocate Region inspection resources as appropriate.
e.
provide to the Director, Office of inspection and Enforcement, recommendations for improvements to the SALP prog ram and comments on proposed changes to SALP policy.
0516-04 EVALUATION CRITERI A AND FUNCTIONAL AREAS
(
041 Evaluation.
Licensees will be evaluated in the functional areas listed in Section 042 using the criteria provided herein and further amplified in the appendix to this chapter.
Each functional area evaluated will be assigned a Category as defined in Section 043.
Not all functional areas need be covered in a given review.
If a functional area appropriate to a licensee is not covered, the reasons should be given in the report.
The appendix to this chapter lists a number of attributes for each evaluation criterion.
The f unc tional area being evaluated may have some attributes that would place the evaluation in Category 1 and others that would place it in either Category 2 or 3.
The final rating for each functional area will be a composite of the attributes tempered with judgment as to the significance of individual items.
Departures from this guidance may sometimes be warranted.
In such cases, the rationale for such departures should be explained in the report.
042 Functional Areas.
A grouping of similar activities.
a.
Operating Phase Reactors 1
Plant Operations Consists chiefly of the activities of the licensee's operational staff (e.g.,
licensed ope rators, shift technical advisors, and auxiliary ope rators ).
It is intended to be limited to operating activities such as:
plant startup, power operation, plant shutdown, and system lineups.
Thus, it includes activities such as reading and logging plant cond:tions; responding to Approved :
July 25,1986
)
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE N R C -0516-044 c.
Category 3 Both NRC and licensee attention should be increased.
Licensee management attention or involven.ent is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety and construction quality is being achieved.
044 Trend.
The SALP Board may determine to include an appraisal of the performance trend of a functional area.
Normally, this performance trend should only be used where both a definite trend of performance is discernible to the Board and the Board believes that continuation of the' trend may result in a change of performance level.
The Board's appraisal of the performance trend, if used, should appear as a Board Comment, it should be used selec-tively and should be reserved for those instances where the Board believes that it is necessary to focus NRC and licensee attention on an area be-cause of a declining performance trend, or to credit licensee performance because of an improving trend.
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.
045 Evaluation Criteria. Elements which must be considered when assessing a licensee's performance in a functional area, a.
The evaluation criteria are as follows:
1.
Management involvement in assuring quality 2.
Approach to the resolution of technical issues from a safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Operational and Construction events (including response to, i
analysis of, and corrective actions for) l l
6.
Staffing (including management) l I
b.
Guidance for using these criteria to arrive at a
category assignment is found in the appendix to this chapter.
Approved:
July 25, 1986
SYSTEMATIC ASSESSMEN T OF N R C -0516-05 LICENSEE PERFORMANCE 0516-05 B ASIC REQUIREMENTS I
051 Applicability.
This chapter applies to and shall be followed by NRC Headquarters Offices and Regional Offices.
052 Appendix 0516.
Procedures for implementation of these directives are presented in the appendix to this chapter.
I-4 t>
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A pproved :
July 25,1986
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE N R C -0516- 042a. 2 off-normal conditions; manipulating the reactor and auxiliary controls; plant-wide housekeeping; and control room professionalism.
2.
Radiological Controls includes the following areas of activity which may be evaluated as separate subareas to arrive at a consensus rating for this functional area.
includes controls by li-(a) Occupational Radiation Safety censees and contractors for occupational radiation pro-tection, radioactive materials and contamination controls, radiological surveys and monitoring, and ALARA programs.
(b) Radioactive Waste Management - includes processing and on-site storage of gaseous, liquid and solid wastes.
(c)
Radiological Effluent Control and Monitoring includes gaseous and liquid effluent controls and monitoring, offsite dose calculations and dose limits, radiological environmental monitoring, and the results of N R C's confirmatory measurements program.
(d) Transportation of Radioactive Materials - includes procure-ment and selection of packages, preparation for shipment, selection and control of shippers delivery to carriers, receipt / acceptance of shipments by receiving
- facility, periodic maintenance of packagings and, for shipment of spent fuel, point of origin safeguards activities.
(e) Water Chemistry Controls.- includes primary and secondary systems affecting plant water chemistry water chemistry control prog ram and program implementation, chemistry facilities, equipment and procedures, and chemical analysis quality assurance.
3.
Maintenance includes all licensee and contractor activities associated with preventive or corrective maintenance of instrumentation and control equipment and mechanical and electrical systems.
4.
Surveillance includes all surveillance testing activities as well as all inservice inspection and testing activities.
Examples of activities included are:
instrument calibrations, equipment operability tests, containment leak rate tests, special tests, inservice inspection and performance tests of pumps and valves, and all other inservice inspection activities.
Approved :
July 25, 1986
SYSTEMATIC ASSESSMENT OF N R C -0516-042a. 5 LICENSEE PERFORMANCE l
S.
Fire Protection 1
Includes routine housekeeping (combustibles, etc.) and fire protection / prevention program activities.
Thus, it includes the storage of combustible material; fire brigade staffing and training; fire suppression system maintenance and operation; and those fire protection features provided for structures, systems, and components important to safe shutdown.
6.
Emergency Preparedness includes activities rNating to the implementation of the emer-gency plan and implementing procedu res.
Thus, it includes -
such activities as licensee's performance during exercises which test the licensee,
- state, and local emergency plans; plan administration and implementation; notification; communications; facilities and equipment; staffing; training; assessment; emergency classification; medical treatment; radiological expo-sure control; recovery; protective actions; and interfaces with onsite and offsite emergency response organizations.
7.
Security includes all activities whose purpose is to ensure the security of the plant.
Specifically it includes all aspects of the licensee's security program (e.g.,
access control, security
(
checks, safeguards).
8.
Outages includes all licensee and contractor activities associated with major outages.
- Thus, it includes refueling, outage management, major plant modifications, repairs or restoration to major components (e.g.,
steam generator tube repairs or primary loop piping replacement), and all post-outage startup j
testing of systems prior to return to service.
j 9.
Quality Programs and Administ~ative Controls Affecting Quality includes all management control, veriT: ation and oversight activities which affect or assure 15 3 quality of plant activities, structures, systems, and components.
This area may be viewed as a comprehensive management system for controlling the quality of work performed as well as the quality of verification activities that confirm that the work was performed correctly.
The evaluation of the effectiveness of the quality assurance system should be based on the results of management actions to ensure that necessary people, procedures, facilities, and materials are provided and used during the operation of the nuclear power plant.
Principal emphasis should be given to evaluating the effectiveness and involvement of management in
)
establishing and assuring the effective implementation of the quality assurance program along with evaluating the history of Approved:
July 25,1986 i
~
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE N R C -0516-042b. 6 l-6.
Electrical Equipment and Cables locludes safety-related electrical components, cables and asso-ciated items used in the electrical systems of the plant, such as; motors, transformers, batteries, emergency diesel genera-tors, motor control centers, switchgear, electric raceways, cable (power, control, and instrument), circuit breakers, relays, and other interrupting and protective devices.
7.
Instrumentation Covers safety-related instrument components and systems that are designed to measure, transmit, display, record and/or control various plant variables and conditions. The Reactor Protection System and the Engineered Safety Features Actuation System are two plant systems utilizing such devices as:
sen-sors, transmitters, signal conditioners, controllers and other actt.ating devices, recorders, alarms, logic devices, instru-ment air supplies, racks, and panels.
8.
Quality Programs and Administrative Controls Affecting Quality includes all management control, verification and oversight activities which affect or assure the quality of plant structures, systems, and components.
This area may be viewed as a comprehensive management system for controlling the quality of work performed as well as the quality of verification activities that confirm that the work was performed correctly.
The evaluation of the effectiveness of the quality assurance system should be based on the results of management actions to ensure that necessary people,
procedures, facilities, and materials are provided and used during the design and construction of the nuclear power plant.
Principal emphasis should be given to evaluating the effectiveness and involvement of management in establishing and assuring the effective implementation of the quality assurance program along with j
evaluating the history of licensee / contractor performance in j
the key areas of:
quality assurance prog ram, design and i
procurement
- control, control of construction processes, inspections, audits, corrective action systems, and records.
9.
Licensing Activities Includes all activities supporting the NRC review of the application for and the issuance of the Construction Permit and l
Operating
- License, and amendments thereto.
It includes the NRC review of exemption requests, relief requests,
schedular extensions, responses to generic letters and bulletins,
and TMI (NUREG-0737) Actions.
In
- addition, it includes an assessment of licensee activities related to design and safety issues.
It also includes NRC meetings that dealt with significant licensing issues.
Approved :
July 25, 1986
SYSTEMATIC ASSESSMENT OF N R C-0516-043 LICENSEE PERFORMANCE 10.
Others ( As needed) c.
Preoperational Phase Reactors 1.
Preoperational Testing Covers the preparation, conduct, and evaluation of test results for preoperational tests performed by or under the direction of the licensee's staff to demonstrate the proper functioning and conformance to design requirements of components,
- systems, and st ructu res.
2.
Others ( As Needed)
For reactors in the preoperational phase, functional areas from the listing for either operating phase reactors or construction phase reactors should be selected as appropriate.
l d.
Starts a Phase Reactors 1.
Startup Testing Covers the preparation, conduct, and evaluation of test results for testing conducted following the issuance of the operating
- license, it starts with initial fuel loading and precritical tests, and continues until the plant reaches commercial operat-ing status at or
.ar its licensed power rating.
2.
Others ( As Needed)
For reactors in the startup phase, functional areas from the listing for operating phase reactors should be used.
043 Performance Categories. A rating of licensee performance in a given i
functional area, a.
Cacgury 1 Reduced NRC atti ntion may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety and construction quality is being achieved, b.
Category 2 NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety.
Licensee resources are adequate and reasonably 1
effective so that Satisfactory performance with respect to opera-tional safety and construction quality is being achieved.
1 Approved :
July 25,1986
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE N R C -0516-042a.10 licensee performance in the key areas of:
committee activities, design and procurement control, control of design change processes, inspections, audits, corrective action systems, and records.
10.
Licensing Activities includes all activities supporting the NRC review of amendment
- requests, exemption
- requests, relief
- reports, response to generic letters and bulletins, and TMl items classified as:
Multi-Plant
- Actions, Plant Specific
- Actions, and TMI (N U R EG-0737) Actions.
In addition, it includes an assessment of licensee activities related to design and safety issues. It also includes NRC meetings that dealt with significant licensing issues.
11.
Training and Qualification Effectiveness Although this functional area is limited to the following categories of facility training / retraining so as to parallel those training programs covered by the Commission Policy Statement on Training and Qualification, this functional area includes all activities relating to the effectiveness of the training / retraining and qualifications program conducted by the licensee's staff and contractors for these categories of facility training.
Other categories of facility training / retraining should be treated as evaluation criteria for the other functional areas.
(a) Non-licensed operators (b) Control room operators (c) Senior control room operators / shift supervisors i
(d) Shif t technical advisors (e)
Instrument and control technicians (f)
Electrical maintenance personnel (g) Mechanical maintenance personnel (h) Radiological protection technicians (i)
Chemistry technicians (j)
Onsite technical staff and managers 12.
Others ( As Needed)
Approved :
July 25, 1986
<=
SYSTEMATIC ASSESSMENT OF.
N R C-0516-042. b -
LICENSEE PERFORMANCE -
b.
Construction Phase Reactors
(
1.
Soils and Foundations includes all-soil and foundation activities related ~ to the construction of -the ultimate heat sink and safety-related structures.
Specifically, this covers, as applicable, subgrade i
investigation and. preparation, fill materials and compaction, l
emban kments,- foundations and associated laboratory testing, l
and instrumentation and monitoring systems.
2.
Containment, Safety-Related Structures, and Major Steel Supports includes all activities related to the structural concrete and steel used in the containment (including the basemat) and safety-related structures, and major steel equipment supports.
It includes all aspects of structural concrete (e.g., reinforcing steel; concrete
- batching, delivery, placement, in-process testing, and curing; liner plate erection and fabrication; and containment post-tensioning), structural steel used in safety-related structures (welded and bolted), and major steel equip-ment supports (for reactor vessel, reactor coolant pumps, steam generators, pressurizer, polar crane, tanks, heat exchangers, etc.),
3.
Pipino Systems and Supports
(
I includes those. safety-related piping systems described in 10 CFR 50.2(v) and R.G.1.26, quality groups A, B and C.
It 1
is intended to be limited to the primary pressure boundary and other safety-related water, steam and radioactive waste containment piping systems.
It includes those quality checks necessary to ensure compliance with the applicable codes and other requirements specified in the SAR for these systems.
The primary inspection emphasis in this area is on piping systems and their supports / restraints.
]
1 4.
Safety-Related Components - Mechan _ical
)
Covers raechanical components such as pressure vessels, pumps, and valves located in, and attached to, the piping systems described in 3, above. The primary emphasis' here is on com-ponents rather than piping.
5.
Auxiliary Systems Includes those safety-related auxiliary systems included in the nuclear facility which are essential for the safe shutdown of the plant or the protection of the health and safety of the public.
Included here are systems such as HVAC, radwaste, fire protection and fuel storage and handling.
Approved :
July 25, 1986 k________________________
/'
QL
. SYSTEMATIC ASSESSMENT OF' LICENSEE PERFORMANCE NRC Appendix 0516 PART I t;
'l GENERAL A.
The SALP program was established to. improve the NRC Regulatory ;
i I
' P rog ram, tot permit sound decisions regarding NRC -resource allocations, and-to better understand the reasons for the performance of each reactor licensee.
1
- B.
The NRC will conduct a review and evaluation of each power reactor licensee possessing an-operating license or construction permit every.
18 months except:
1.
When the Regional Administrator determines that a particular. utility or facility should be evaluated more frequently.
Licensees which were assigned Category 3 performance in several functional areas during the previous. evaluation period should be considered for eval-uation on an annual basis.
2.
When.a SA.LP Report will be used as part of an evaluation of readi-i ness for license issuance (IE 94300), a SALP. evaluation should be l
scheduled approximately six months before the scheduled licensing date.
3.
When a new operating license is issued, two SALP evaluations should be scheduled at approximately 12 months intervals.
The first of
~
these two evaluations should be scheduled for completion approxi-mately 12 months after the SALP evaluation conducted-during the preoperational phase just prior to issuance of the operating license.-
The second. of these two evaluations should be completed approximately 12 ' months later.
Following completion of these two evaluations, it is expected that most facilities would then be placed on a normal schedule.
The individual facility assessments are intended to take place at an approximately uniform rate throughout the year within each Regional Office.
C.
The evaluation process is composed of (Figure 1, Part I):
1.
A SALP Board assessment.
2.
Issuance of the SALP report.
3.
If requested by the licensee or if otherwise determined to be i
necessary by the Regional Administrator, a meeting with licensee management to discuss the assessment.
A licensee management meeting should be considered t:y the Regional Administrator in those cases where it appears that licensee performance is such that an 1
Approved:
July 25, 1986 i
NRC Appendix 0516 SYSTEMATIC ASSESSMENT OF Part i LICENSEE PERFORMANCE order imposing a Regulatory improvement Program or other sanctions may be appropriate.
4.
Consideration of any written response received (or required ) from the licensee and issuance of an appendix to the SALP report which is to include the verbatim written response received from the licensee and the conclusions of the Regional Administrator en the basis of his consideration of the response.
D.
Procedures for implementing the SALP program are provided in this appendix.
Approved :
July 25,1986 2
L.
~
SYSTEMATIC ASSESSMENT OF NRC Appendix 0516 L
LICENSEE PERFORMANCE Part I FIGURE 1 SALP Evaluation Process SALP Board Preparation (Part Ill)
SALP Board Meeting (Part Ill)
SALP Report Issuance (Part V)
Meeting with the Yes Licensee?
No Meeting with the Licensee (Part IV)
Licensee
]
Responds Appendix to the SALP Report (Part VI) i 3
Approved :
July 25,1986 i
SYSTEMAT'lC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516 PART li EVALUATION CRITERI A The assessment of licensee performance is implemented throu0h the use of six evaluation criteria.
The criteria provide standard guidance that shall be applied to each functional area for the categorization of licensee performance.
l l
To provide consistent evaluation of licensee performance, several attri-I butes associated with each criterion are listed to describe the character-istics applicable to the three categories.
The six criteria discussed in Chapter N RC-0516-045 are listed in Table 1 with their associated attributes.
These form the guidance which aids in understanding and evaluating license.e performance by identifying the causes and factors appropriate for categorization.
It is not intended that con-sideration of these attributes influence established programs of the agency.
For example, it is not. intended that specific inspections be j
performed to evaluate attributes.
It is expected that during the implemen-tation of established p rog rams, many of the attributes which describe per-formance will be observed.
Cognizance of these attributes should assist the staff in their observation of licensee performance during routine activities.
All of the attributes of the evaluation criteria are not necessarily appli-
- cable, in some instances, the observed performance within a functional area may be insufficient to allow consideration in the evaluation.
How-ever, matters such as management involvement and staffing are criteria of i
each functional area and should be considered in the evaluation of the functional areas.
It is emphasized that all available information should be analyzed by the SALP Board, and its significance, whether it be positive or negative, should be weighed.
If information is scarce or nonexistent, a decision regarding the performance category as it relates to an attribute should not be forced.
I I
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5 Approved :
July 25, 1986 j
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SYSTEMATIC < ASSESSMENT OF
~
LICENSEE PERFORMANCE NRC Appendix 0516
' P ART 'lli SALP BOARD ASSESSMENT A.
SALP Boaro Preparation Each Region shall:
-1.
Issue a memorandum establishing the assessment period, SALP Board input due date, SALP Board meeting date, and expected date of '
licensee meeting, 'if necessary, for all facilities ' within.the Region for ' all SALP meetings scheduled to occur in the calendar year.
This memorandum shall be sent to NRR, IE, NMSS, AEOD, 'and the EDO by the end of.the preceding calendar year.
Changes to SALP
~
schedules should - also be provided to these Offices.
SALP Board members shall be notified promptly ' of. unavoidable schedule problems to facilitate coordination of setting alternate meeting dates.
2.
Prepare a draft of the SALP Board Report.
a.
Obtain SALP Board inputs.
NRR shall. provide a written input to the Licensing Activities area. and should. provide, as P
appropriate, written inputs to other functional areas.
Other prog ram offices should - ~ provide -any known-significant information based upon Headquarters activities.
b.
Prepare the. Supporting Data Summary section of the report.
(See Part Vil; Exhibit 2,for format. )
Prepare a performance analysis for each of the functional areas c.
identified in N R C - 0516-042.
(See Part Vil, Exhibit 2, for format. )
d.
Issue a draft of the SALP Board Report to meeting participants in advance of the SALP Board Meeting date.
B.
SALP Board Meeting 1.
The S ALP Board meeting should be conducted within 45 days of the
~
end of the assessment period.
This meeting will be conducted under a regionally generated SALP Board procedure.
2.
The SALP Board shall be composed of the following voting members SALP Board Chairman (Division level manager or above) a.
b.-
NRR Project Manager 11 Approved :
July 25,1986
+
t
' NRC Appendix 0516 '
SYSTEMATIC ASSESSMENT OF-Part 'l11 '
LICENSEE PERFORMANCE c.
NR R. management representative.
d.
Senior Resident inspector.
e.
. R representatives from IE, AEOD, and NMSS when ' determined l
appropriate' by' the' respective Office Director-f.
, Other Individuals as determined by the Regional Administrator-g; Regional Administrators are encouraged to-arrange _ for the occasional participation 'of Division level managers - from other -
Regions 'on SALP Boards.
~
3.
During the SALP Board meeting, the SALP Board shall:
l-a.
Review and discuss the draft SALP Board Assessment report.
Ensure that sufficient information has been provided in each functional area -analysis to form a conclusion regarding licensee performance or : alternatively confirm that sufficient information is. not available to support a conclusion - regarding licensee performance, b.
Rate. licensee performance in each functional area after consid-ering' the evaluation criteria with. their. associated attributes listed in Table ' 1 of Part.ll of this appendix.
Tables PL and 3 may be used by the SALP Board members to assist them in their -
rating of a.' licensee.
Ratings shall be determined by majority vote of the Board's voting members.
c.
Recommend changes to the inspection prog ram emphasis, as necessary.
. Approved:
July 25,1986 12
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SYS7 EMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516 PART IV MEETING WITH LICENSEll.
4 s
A.
General.
If ' requested by the licensee or if otharwise determined to be necessary by the Regional Administrator, a meeting with licerkde manage-ment to discuss the a.nessment will be held.
B.
Meeting Preparation 1.
Notification of the meeting (if held) should be made by the Region to the
- licensee, the cognizant Regional personnel, the resident
. [,
inspectors at th? Mvolved facilities, the NRR Project Managers for T
the involved f acilities, and cognizant NRC managers.
g s'
,1 2.
The licensee saould be encouraged tr.have tr.e following management i
representatives participate in the meeting.
i q
Senior corporate mar /agement representative a.
b[
Management officials responsible for the major functions wherein
',f y
pt oblem areas have been identified (e.g.,
health physics, M
security, engineering)
N
?
c.
Site Manager 3
C.
Meeting with Licensee 3
1.
The meeting (if held) should be concocted within 90 days'~of the end 4
of the dssessment period.
2.
N4C representatives for this meeting should include the following:
a.
Either the Regions Administrator, ' Deputy Administrator, or a Division Director s
b.
Responsible Regional Division Director (s), Branch C hief s, or
'Section Chiefs, as appropriate NRR Project Manager and designated flhR manager c.
'd.
Resident inspector and/or assigned.. inspectors eq
?p.
Public Affairs Officer, when media interest is anticipated j
s'
- > i '*
3.
The Regional Administrator, Deputy A drr.ini st rator,
or Division Dire" tor will chair the meeting and discussmns of the adequacy of the licensee's management controls.
These meetings are intended to provide a foru.a for candid discussion of issues relating to the licensee's performance'.
Those aspects of the licensee's Aration
\\
I 15 Approved:
July 25,1986
{ s.
N mv
.x
NRC Appendix 0516 SYSTEMATIC ASSESSMENT OF Part lV LICENSEE PERFORMANCE
)
i that need improvement will be identified.
The good aspects of the
(
licensee's performance should also be identified.
The licensee will also be given the opportunity to make comments on the report in writing within 30 days after the meeting or receipt of the SALP Board report if no meeting is held.
Only written comments from the licensee must be addressed by the Regional Administrators.
4.
SALP management meetings with the licensee should be conducted as open meetings, with the exception of those portions of the meetings that involve discussion of the matters not required to be mandatorily placed in the public domain pursuant to 10 CFR 2.790, which must be closed.
Members of the public should be treated as observers.
Adequate notification of the SALP meeting can be accomplished by PDR distribution of the letter to 'the licensee which schedules the meeting, with comes to the service list for the appropriate docket.
Approved :
July 25, 1986 16
hiYSTE MATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516 l
l l
PART V ISSUANCE OF REPORT j
i A.
Issuance of Report The SALP Board Report (Exhibit 2,
Part Vil) shall be issued to the licensee under signature of the Regional Administrator with copies to
- Director, IE;
Tha transmittal letter should include:
1.
A request for the licensee's written comments and amplification, as appropriate, on the SALP report within 30 days after the licensee meeting (if held) or receipt of the SALP Board report.
For all functional areas rated as Category 3,
the transmittal letter shall require a licensee response providing planned corrective actions to achieve improved performance.
2.
Amplification of the findings of the SALP Board as appropriate.
This includes, as a minimum, functional areas rated Category 1,
Category 3, and those functional areas which have declined since the last SALP evaluation period (examples are shown in Exhibit 1,
Part Vil).
3.
A characterization of overall safety performance.
This letter, enclosing the SALP Report, will receimmc.cdM fiocket distribution including the NRC Public Document Room and the local Public Document
Each report will be assigned an inspection Report number.
B.
Changing the SALP Report Any changes made to the report as originally transmitted to the licensee shall be done using the following procedure (an example is shown in Exhibits 3, 4, and 5, Part Vll).
l l
Include an errata sheet (Exhibit 3, Part Vil) as a separate enclosure a.
to a Regional Administrator's cover letter denoting the change and the basis for the change.
b.
Add the corrected page (Exhibit 5, Part Vil) to the report, leaving the original page (Exhibit 4, Part Vil) in the report, c.
Make a diagonal line th rou g h the original page, referencing the l
Errata sheet.
17 Approved :
July 25,1986 l
1 l
j
\\,
i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE NRC Appendix 0516 i
PART VI APPENDIX TO THE SALP REPORT A.
General The Regional Administrator shall issue an appendix to the SALP report within 30 days of receipt of the licensee's written comments or planned corrective actions.
This appendix will receive standard docket distribu-tion including the NRC Public Document Room, the local Public Document Room and INPO.
B.
Appendix to the SALP Report The appendix to the SALP report shall consist of:
1 -.
The verbatim written comments received from the licensee.
2.
A summary of any meetings held with the licensee concerning the SALP report.
3.
Comments on the acceptability of licensee's planned corrective actions, if required.
4.
The conclusions of the Regional Administrator on the basis of his consideration of. the licensee's comments or planned corrective actions.
19 Approved :
July 25, 1986
SYST EMATIC ASSESSMENT OF
[
LICENSEE PERFORMANCE NRC Appendix 0516 PART Vil SALP REPORT FORMAT AND CONTENT A.
General The SALP Board repor1 is considered to be a final report upon approval by the Board, signature of the transmittal letter by the Regional Administrator, and dispatch to the licensee.
B.
Multiple Facility Licensees in cases such as Duke, TVA, and Commonwealth Edison, the SALP package may address more than one site.
However, each site should have a separate SALP Board Report (Exhibit 2, Part Vil).
C.
Report Format and Content The SALP Board report shall be prepared in general conformance to the guidelines provided in Exhibit 2.
The standard entries described in this Exhibit should be used to the extent possible.
I 21 Approved:
July 25,1986
= - _ - - _._ - _ - _ _ - _
?
Y L SYSTEMATIC ASSESSMENT OF_
-NRC Appendix 0516 i
LICENSEE PERFORMANCE Part Vil EXHIBIT 1 Samples of Overall Safety Performance Characterizations Example 1 Overall, we find that your. performance of licensed. activities generally is acceptable and directed toward safe facility operation In addition, your overall performance has shown only moderate. improvement since the last SALP evaluation period. -Your performance in the area of Plant Modifications with. contractors having limited experience was found to be in need of increased management attention.
Example 2 in addithn to the assessments and recommendations made by the SALP Board in the enclosed SALP Report, it is my view that your overall regulatory performance continued at-a high level during the assessment period. It is evident that safe operation and compliance witn regulatory requirements are priority considerations at your facility'.
I concur, however, with the SALP Board findings that management attention is required to correct problems in the area of Radiological Controls and the long standing problems associated with the existing perimeter alarm system.
Example 3 The overall performance of your facility was acceptable but exhibited a declining trend since the last SALP evaluation period. Resources were strained or not effectively used such that minimally satisfactory performance with respect to operational safety was achieved. The SALP Board identified weaknesses in the areas of plant operations, radiological controls, mainte-nance, security and safeguards, and _ the quality assurance program. Your performance in these areas will be closely monitored and discussed in the next SALP Board Assessment for your facility. A major strength was noted in the area of refueling.
Example 4 Overall, we found your performance acceptable and directed toward safe f acility operation.
In addition, we found your overall performance improved
]
since the last SALP evaluation period.
We found aggressive management attention and a high level of performance in the following areas: Radio-logical. Controls, Surveillance, Fire Protection and Housekeeping, Emergency Preparedness, and Refueling. Your performance in assuring that equipment and procedural changes are adequately controlled was found to need increased attention on your part and we will pay particular attention to this area during our subsequent inspections.
23 Approved:
July 25, 1986 a__-_-____-
I
~
NRC Appendix 0516 SYSTEMATIC ASSESSMENT OF Part Vil LICENSEE PERFORMANCE r
EXHIBIT 2 SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION REGION [ Region)
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
[ Inspection Report Number]
[Name of Licensee)
[Name of Facility]
[ Assessment Period]
i Approved:
July 25,1986 24
.7
.. SYSTEMATIC' ASSESSMENT OF-NRC. Appendix 0516 LICENSEE PERFORMANCE' Part Vli 6
EXHIBIT 2 (Cont'd)-
1.
INTRODUCTION The Systematic Assessment of Licensee Perf'ormance (SALP) program. is an integrated NRC staff effort to collect available observations and data on a periodic basis and to - evaluate licensee-performance ' based upon this information.
The SALP program is supplemental to normal regulatory
' processes used to ensure compliance. with NRC rules and regulations.
The SALP program is intended to be sufficiently diagnostic to provide a '
rational basis.for. allocating NRC resources and to provide meaningful-guidance to the licensee's management ~ to promote quality and safety of ~
plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on
[date), to review the collection of performance observations and data, and to: assess licensee performance in 'accordance with the guidance in Chapter
' NRC C516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in. Section 11 of this report.
This report is the SALP Board's assessment of the ' licensee's - safety performance at (name of facility] for the period {date] through [date).
SALP Board for (name of facility]:
[ List SALP Board Members]
l l
i 25 Approved :
July 25, 1986
NRC Appendix 0516 SYSTEMATIC' ASSESSMENT OF Part Vil LICENSEE PERFORMANCE l
1 l
l I
EXHIBIT 2 (Cont'd)
II.
CRITERIA Licensee performance is assessed in selected functional areas, depending upon whether the facility is in a construction, preoperational, or operating phase.
Functional areas normally represent areas significant to nuclear safety and the environment.
Some functional areas may not be assessed because of little or no licensee activities, or f ack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement and control in assuring quality 2.
Approach to the resolution of technical issues from a safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history
(
S.
Operational and Construction, events (including response to, analyses of, and corrective actions for) 6.
Staffing (including management)
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories.
The definitions of 4
these performance categories are:
1 Category 1.
Reduced NRC attention may be appropriate.
Licensee l
management attention and involvement are aggressive and oriented j
toward nuclear safety; licensee resources are ample and effectively used I
so that a high level of performance with respect to operational safety and construction quality is being achieved.
Category 2.
NRC attention should be maintained at normal levels.
l Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory perfortnance with respect to operational safety and construction quality is being achieved.
i J
A pproved :
July 25,1986 26 1
i
SYSTEMATIC ASSESSMENT OF NRC Appendix 0516 LICENSEE PERFORMANCE Part Vit EXHIBIT 2 (Cont'd)
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety and construction quality is being achieved.
Ill.
SUMMARY
OF RESULTS
[ Provide a narrative summary of the licensee's overall significant strengths and weaknesses.
It should be similar to the overall performance narrative used in the letter to the licensee.]
Functional Area
[last period]
[this period]
[ functional area]
[ rating last
[ rating this period ]
period]
I IV PERFORMANCE AN ALYSIS A.
[ Functional Area being discussed) 1.
Analysis
\\
[The analysis of the licensee's performance in an area
]
should include pertinent facts and observations to highlight the specific strong and weak aspects of the licensee's performance.
These facts and observations shall be presented in a manner to place matters in perspective and to allow the reader to understand the rationale for stated conclusions.
This analysis should concentrate on the adequacy of the licensee's management control sys tems, adequacy of resources, training j
of personnel, etc.,
and the effectiveness of these efforts.
l Upon presentation of the analyses, the attributes associated with the specified criteria are to be referred to for purposes of both completeness and to compare the conclusions reached with the attributes of each category.
The attribt/tes listed in Part 11 are specifically oriented toward this and should be utilized.
in no event, however, are the examples of licensee j
performance for specific attributes to be used as stand-alone j
1 27 Approved :
July 25,1986 l
l J
NRC Appendix 0516 SYSTEMATIC ASSESSMENT OF Part Vil LICENSEE PERFORMANCE i
EXHIBIT 2 (Cont'd) assessments; they represent a sampling of possible conclusions which must be supported by appropriate facts, observations or analysis.
Each analysis should be written to avoid either 10 CFR 2.790 or safeguards information.
The analysis section is composed of three major subsections:
A brief account of the inspection activity which occurred in this area.
A brief summary of the previous evaluation if there has si nificant change or if there should have been been a 0
significant improvement but there was not.
A summary of the strengths, weaknesses, and other significant observations made by the NRC staff during the evaluation period.
2.
Conclusion
[ Provide the performance assessment (Category 1, 2, or 3) for each functional area considered.]
3.
Board Recomm9ndations
[ Include any general or specific Board recommendations per-taining to either licensee management attention or NRC inspection activities in a functional area.
If appropriate, include a
trend assessment (improving or declining),
characterizing licensee performance near the close of the assessment period.
Note that even in the absence of a recommendation to vary inspection levels, the Regional Office may do so based on the assessment as discussed in appropriate chapters of the IE manual.]
V.
SUPPORTING DAT A AND SUMMARIES l
A.
Licensee Activities
[ Provide an outline of major licensee activities, such as major
- outages, power limitations, important license amendments, and significant modifications. ]
B.
Inspection Activities
[ Provide a summary of major inspection activities in each functional area.
This is not intended to be a summary of each routine inspection performed, but rather a summary of major inspection activities such as team inspections.
Include Table 1. ]
App roved :
July 25, 1986 28 I
l SYSTEMATIC ASSESSMENT OF NRC Appendix 0516 i
LICENSEE PERFORMANCE Part Vil 9
l l
l EXHlBIT 2 (Cont'd)
C.
Investigations and Allegations Review
[ Provide a summary of major investigative activities and their I
results. ]
D.
Escalated Enforcement Actions 1.
Civil Penalties (Provide a summaryj 2.
Orders (only those relating to enforcement) [ Provide a summary)
E.
Licensee Conferences Held During Appraisal Period
[ Discuss conferences that dealt with regulatory performance or enforcement. ]
F.
Confirmation of Action Letters
[ Provide a summary. ]
G.
[Other]
[ Discuss any other issues at the discretion of the SALP Board.}
H.
Review of Licensee Event Reports, Construction Deficiency Reports, and 10 C F R 21 Reports Submitted by the Licensu
[ Provide a
brief summary of significant findings and trends resulting from a review of these reports. If this information is contained in another section of the report, this item may be omitted. )
1.
Licensing Activities
[ Provide a summary of significant occurrences in each of the follow-ing categories of NRR licensing activities. The summaries should provide a basis that demonstrates the significance of the licensee's programs, and the importance and resources assigned by the licensee to the programs. )
1.
NRR/ Licensee Meetings
[ Discuss meetings that dealt with significant licensing issues.]
2.
Commission Meetings [ Discuss meetings that dealt with signif-icant licensing issues. ]
3.
NRC Site Visits
[ Discuss visits that dealt with significant licensing issues. ]
4.
Schedular Extensions Granted 29 Approved:
July 25, 1986
-_-_-_____-_._______________a
i
)
(
NRC Appendix' 0516 SYSTEMATIC ASSESSMENT OF
(.
Part Vit LICENSEE PERFORMANCE I
(-l.
5.
Reliefs Granted
(
6.
Exemptions Granted 7.
Emergency Actions Granted l
8.
License Amendments issued
)
9.
Orders issued
{
10.
Issues Pending j
1 l
l l
l i
(
1 l
l 1
i f
l l
Approved:
July 25,1986 30 f
_ _ _________-_ U t
NRC Appendix 05'l6 SYSTEMATIC ASSESSMENT OF Part Vil LICENSEE PERFORMANCE
+
(
EXHIBIT 3 AN ERRATA SHEET SALP BOARD REPORT ERRATA SHEET i
PAGE LINE NOW READS SHOULD READ 5
24 operator's cognitive decision operator's decision Basis:
The word cognitive was deleted to avoid further problems in inter-preting its meaning.
As used, the word was intended to mean that the operator, as the cognizant individual on shift, knew the operating requirements of the Technical Specification but made a conscious decision to operate the plant in a manner which he felt was equivalent to the requirements, it was not intended to mean that the operator took actions in total disregard of the Technical Specification objectives.
l l
Approved : July 25, 1986 32 4
l r
i SYSTEMATIC ASSESSMENT OF NRC Appendix 0516
'I LICENSEE PERFORMANCE Part Vil e
O l
EXHIBIT 2 (Cont'd)
TABLE 1 ENFORCEMENT ACTIVITY FUNCT ION AL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL AREA V
IV 111 ll l
TOTAL 31 Approved:
July 25,1986 t1_-----__
SYSTEMATIC ASSESSMENT OF NRC Appendix 0516
' LICENSEE PERFORMANCE Part Vil 7
I l
EXHlBIT 4 ORIGINAL PAGE
- 0) Severity Level IV - Failure to take timely and proper corrective action following the failure of a cold leg RTD (50-000/81-24).
(11) everity Level VI - Failure to make a 30 day report on a degraded b s voltage relay (50-000/81-26).
Six of the oncompliances were for failure to make required reports or to make time reports, four for failure to follow procedures, and one for incomplet documentation. One noncompliance for failure to properly report a breach in containment, Item (9) above, is part of an escalated enforcement actio th Civil Penalty.
The actual event, is described in Section 4, Surv ance.
Nine LER's elating t this area were caused by personnel errors, six i
at Unit 1 and three at 2.
Sixty percent of these occurred in'the last half of.the perio M thirty percent in the last quarter indicat-
'ing an increasing occurFTn rate in the period.
Six of the nine were for incorrect valve or b k
lignments and three ware for failure to follow operating procedu Two events (LER's 50-000/81 '
50-000/81-52) were of particular concern since they reflected a lic d operator's cognitive decision to operate a system (charging and -g>
and containment isolation, respectively) in a manner not allo the Technical Specifications.
ring the evaluation period, Unit 1 experienced nine automatic tri four caused by operator error and five quipment failure.
Of the four caused by errors, two were due to in ctly conducted instrument surveillance tests, one to an incorrect va ineup on the steam side, l
and the last to unfamiliarity with turbine is.
l Unit 2 experienced nine reactor trips, one bei.
a manually initiated
)
Four of the trips were related to per nnel errors; two by loss of vacuum in the main condenser, one resulted om a low steam generator level, and one resulted from a turbine valve misalignment.
I No significant safety concern is associated with these tr1 s and each j
was reviewed to verify proper safety system operation an operator actions.
Various operating problems and events identified during the p iod resulted in an enforcement meeting on August 4, 1981, with follo up meeting on August 4, 1981, with followup meetings on November 2,191 5
33 A pproved :
July 25, 1986 I
]
3 NRL Appendix. 0516 SYSTEMATIC ASSESSMENT OF '
i o
- Part Vil LICENSEE PERFORMANCE e
(
EXHIBIT 5 CORRECTED PAGE t
(10) Severity Level IV - Failure to take timely and proper corrective action following the failure of a cold leg RTD (50-000/81-24).
(11) - Severity Level VI - Failure to make a 30 day report on a degraded bus voltage relay (50-000/81-26).
Six of the noncompliance were for failure to make required reports or to make timely reports, four for failure to follow procedures, and one for incomplete documentation.
One noncompliance for failure to properly report a breach in containment, Item (9) above, is part of an escalated enforcement action with Civil Penalty.
The actual event, is described in Section 4, Surveillance.
Nine LER's relating to this area were caused by personnel errors', six at Unit 1 and three at Unit 2.
Sixty percent of these occurred in the last half of the period and thirty percent in the last quarter indicating an increasing occurrence rate in the period.
Six of the nine were for incorrect valve or breaker alignments and three were for failure to follow operating procedures.
Two events. (LER's 50-000/81-67 and 50-000/81-52) wei, of particular concern since they reflected a licensed operator's decision to operate a system (charging and letdown and containment isolation, respectively) in a manner not allowed by the Technical Specifications.
Unit 1 experienced nine automatic trips during the evaluation period, four caused by operator error and five by equipment failure.
Of the four caused by errors, tWo were due to incorrectly conducted instrument surveillance tests, one to an incorrect valve lineup on the steam side, and the last to unfamiliarity with turbine controls.
Unit 2 experienced nine reactor trips, one being a manually initiated turbine trip.
Four of the trips were related to personnel errors; two by loss of vacuum in the main condenser, one resulted from a low steam generator level, and one resulted from a turbine valve misalignment.
No significant safety concern is associated with these trips and each was reviewed to verify proper safety system operation and operator actions.
Various operating problems and events identified during the period resulted in an enforcement meeting on August 4, 1981, with followup meeting on August 4, 1981, with followup meetings on November 2, 1981 5
l App roved :
July 25, 1986 34 i
j 1
JULY 30, 1986 NRC/80STON EDISON COMPANY MANAGEMENT MEETING AGENDA Plant Status - RHR/LLRT Status Update on SALP Issues Status of 6-Week Management Review Plan to Control Overtime During Startup Overview of Master Startup List Mark I Containment Issues and PNPS Once/ Cycle Surveillance Issue Status of MR Backlog Effectiveness of Maintenance Planning Process Major Outage # Activities I
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