ML20237G520
| ML20237G520 | |
| Person / Time | |
|---|---|
| Issue date: | 02/09/1987 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20237G482 | List: |
| References | |
| FOIA-87-394 RI-1440.1, NUDOCS 8708140110 | |
| Download: ML20237G520 (43) | |
Text
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UNITED STATES
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RI 1440.1/0 Page 1 of 8 REGION I INSTRUCTION 1440.1, REVISION 0 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REFERENCE:
NRC-0516 A.
Purpose.
To prescribe the regional policy and procedures with respect to im-pigmentation of NRC Manual Chapter 0516, Systematic Assessment of Licensee Performance (SALP).
B.
Discussion. The SALP process is intended to be an integrated staff effort
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in which, on a periodic basis, available observations are collected and, based
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on these observations, the performance of the licensee is assessed having considered both positive and negative attributes of the licensee's performance.
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This process is intended to be sufficiently diagnostic as to provide the rational basis for the allocation of regional inspection resources and to provide meaningful objective guidance to licensee management.
C.
Procedure Implementation t
1.
Scheduling Annually, prior to December 1, Director, Division of Reactor Projects shall issue a composite schedule for the following calendar year.
This schedule is illustrated in Figure 1.
The normal assessment period shall be 18 months.
Periods greater than 18 months shall not be scheduled without prior concurrence of the Re-gional Administrator. More frequent assessments of a given licensee or facility may be conducted as recommended by the SALP Board and concurred in by the Regional Administrator. NRC Appendix 0516, Part 1.B should l
be consulted regarding situations in which the SALP Report will be used as part of an evaluation of readiness for license issuance or when a new operating license has been issued.
Experience has shown that scheduling of SALP Boards in September or meet-ings with licensee management in late November or December is counterpro-ductive.
Schedules should be adjusted to avoid SALP Board meetings in September; meetings with licensees should not be routinely scheduled be-tween Thanksgiving and New Years holidays.
Minor adjustments of schedules should be made to conduct assessments at a uniform rate throughout the year having considered the above constraints.
Contact:
D. F. Limroth
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Revision Responsibility:
ORP B708140110 B70812 iO PDR FOIA rg < f SHIMSHAB7-394 PDR A
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n SYSTEMATIC ASSESSMEllT OF LICENSEE PERFORMANCE RI 1440.1/0 Page 2 of 8 Figure 1 Annual SALP Schedule Format m
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SYSTEMATIC ASSESSMENT OF LICENSEE RI 1440.1/0 PERFORMANCE Page 3 of 8 2
SALP Process Schedule The following are milestones in the SALP process. The schedules are limits; efforts are to be made to minimize the time between the close of the assessment period and the issuing of a quality SALP Board Report to the licensee.
Due dates are days, referenced to the date of the close of the assessment period.
Due Date Milestone Responsible Office
-10 Announce SALP Board Meeting Date/
DRP Section Chief Request Board Membership Nominees 0
End of SALP Period
+10 Inputs Due to DRP Section Chief DRS, DRSS, NRR
+25 Issue Draft SALP Board Report DRP Section Chief Issue SALP Board Meeting Notice
+32 Comments Due to DRP Branch Chief DRS, DRSS
+39 Issue Revised Draft SALP Board DRP Branch Chief Report
+45 SALP Board Meeting
+55 SALP Board Report to Regional SALP Board Chairman Administrator
+60 SALP Board Report Transmitted to Regional Administrator Licensee
+70 Meeting with Licensee
+100 Comments Due from Licensee
+110 Issue Comments Relative to DRP Branch Chief Licensee Response 3.
SALP Input Inputs to the SALP process are of two categories:
Periodic highlights of key issues from each inspection report to aid in ensuring that all substantive issues have been considered in the SALP Report.
These also provide timely data points to help assess changes in the licensee's performance pattern in a given functional area.
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SYSTEMATlC ASSESSMENT OF LICENSEE RI 1440.1/0 3
PERFORMANCE Page 4 of 8 Analyses of performance by functional area which form the substance of Section IV of the SALP Board Report.
Responsibility for inputs by functional area is shown in Figure 2.
De-tails of the scope and content of functional area performance analyses are contained in Enclosure 1.
Responsibility for timely submission of performance analyses other than those for.which DRP is responsible, rests with DRS and DRSS.
Each specialist and each resident inspector should review the results of the inspection at the time an inspection report is written and deter-mine whether a preliminary conclusion can be drawn based on significant findings on licensee performance in one or more of the functional areas listed in Figure 2.
If such a preliminary conclusion can be drawn, a summary of the findings and a preliminary conclusion in the form of a SALP Rating (i.e., SALP Rating 1, 2, or 3) shall be prepared for each of these functional areas, as shown on Figure 3, and forwarded to the cognizant Projects Section Chief when the report is forwarded to the licensee.
4.
Draft SALP Board Report The format and generic content of SALP Reports is prescribed in Enclosure 1.
Utilizing inputs received from DRS and DRSS, the NRR Licensing Project Manager and the senior resident inspector, a draft SALP Board Report shall be produced, normally within the cognizant Reactor Projects Section.
NOTE:
The draft SALP Board Report shall not include the narrative Overall Summary of Report Section III nor the conclusions in the Performance Analyses of Report Section IV.
Those shall be produced at the SALP Board Meeting with the Overall Summary normally prepared at the Projects Branch Chief level.
The (first) draft SALP Board Report shall be forwarded by memorandum under the signature of the cognizant Projects Section Chief to persons who provided inputs.
Comments on the draft SALP Board Report :; hall be provided to the cognizant Projects Branch Chief. The Revised Draft SALP Board shall be forwarded by memorandum under the signature of the cogni-zant Projects Branch Chief to members of the SALP Board. Additional copies for staff review should normally be provided by the cognizant l
Reactor Projects Section Chief.
5.
SALP Board The SALP Board shall function in accordance with Enclosure 2.
The SALP Board report shall be forwarded to the Regional Administrator
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by the SALP Board Chairman together with a proposed transmittal letter.
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SYSTEMATIC ASSESSMENT OF LfCENSEE RI 1440.1/0 PERFORMANCE Page 5 of 8 Q; ' !
_ FIGURE 2 FUNCTIONAL AREA RESPONSIBILITIES FUNCTIONAL INPUTS AREA FROM NOTE P1a'nt Operations DRP, DRS 1,4 Radiological Controls DRSS 1,4 Maintenance.
Surveillance DRS, DRP 1,4 Fire Protection DRS, DRP 1,4 Emergency Preparedness DRSS, DRP 1,4
. s.,
Security and Safeguards-DRSS 1,4 Outages DRS, DRP, DRSS 1,4 Assurance of Quality DRP, DRS, DRSS 1,2,3,4 Licensing Activities NRR 1,2,3,4 Engineering Support DRS, DRP 1,2,3,4 Training and Qualification Effectiveness DRP, DRS, DRSS 1,4 Soils and Foundations DRS 2
Containment, Safety-related Structures,.
and Major Steel Supports
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Piping Systems and Supports DRS, DRP 2
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Safety related Components - Mechanical DRS, DRP 2
Electrical Equipment and Cables DRS, DRP 2
Preoperational Testing DRS, DRP 3
Others (as needed) 4 Notes:
General - DRP has responsibility for overall coordination of inputs into a draft SALP Board Report.
1.
Operating Phase Reactors 2.
Construction Phase Reactors 4
3.
Preoperational Phase Reactors.
Functional areas from the listing for either j
operating phase reactors or construction phase reactors should be selected l
as appropriate.
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4.
Start-up Phase Reactors.
Functional areas from the listing for operating j
phase reactors should b+. used.
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SYSTEMATIC ASSESSMENT OF LICENSEE RI 1440.1/0 PERFORMANCE Page 6 of 8 FIGURE 3 1
SALP INPUT REPORT Docket / Report No.:
Functional Area:
Inspection Hours:
Lead Inspector:
SALP Input:
(Provide here a brief summary of significant findings.)
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Conclusion:==
SALP Category (Category to be determined based on criteria of Enclosure 2, Table 1, using Region I Form 197 to document specific justification, as applicable.)
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l SYSTEMATTC ASSESSMENT OF LlCENSEE RI I440.1/0 PERFORMANCE Page 7 of 8 6.-
_ Report Issuance The SALP Board Report shall be issued to the licensee under the signature of the Regional Administrator. The SALP Board Report is considered to be a final report upon approval of the Board, signature of the letter of. transmittal by the Regional Administrator, and forwarding to the licensee.
l The transmittal letter should include:
A request for the licensee's written comments and amplification, as appropriate, on the SALP Report within 30 days after the licensee meeting.
For all functional areas rated as Category 3, the trans-mittal-letter shall require a licensee response providing planned corrective actions to achieve improved performance.
Amplification of the findings of the SALP Board as appropriate. This includes, as a. minimum, functional areas rated Category 3 and those functional areas which have declined since the last SALP evaluation period.
A characterization of overall safety performance.
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The letter forwarding the SALP Board Report will receive standard docket
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distribution including the following:
Director, IE Directne, NRR Chairman, NRC Commissioners (4),NRC NRC POR Local PDR INP0 (Record Center, INP0)
Meeting With Licensee A meeting with licensee management for the purpose of candid discussions of issues relating to the licensee's performance will normally be held within 70 days of the close of the assessment period.
Details concerning this meeting are contained in Ecclosure 3.
8.
Changes to the SALP Board Report As stated in 5 above, the SALP Board Report is considered a final report upon transmittal to the licensee.
Should it be deemed appropriate to amend the report following a meeting with the licensee and/or receipt
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of written comment, the procedures detailed in Enclosure 4 shall be fol-lowed.
SYSTEMATIC ASSESSMENT OF LICENSEE RI 1440.1/0 PERFORMANCE Page 8 of 8 D.
Effective Date This instruction supersedes Regional Office Instruction 0501.5, and is effec-tive upon issuance.
Approved:
Thomas E. Murley v_
Regional Administrator
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Date:
Enclosures:
1.
SALP Board Report Format and Content 2.
The SALP Board 3.
Licensee Management Meetings 4.
SALP Board Report Amendments Distribution:
Office of the Regional Administrator i
Division Directors Chief, Administrative Management Branch (original)
Resident Offices I
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SYSTEMATIC ASSESSMENT OF- -
c, LICENSEE PERFORMANCE-RI 1440.1/0 ENCLOSURE 1 SAlp BOARD REPORT FORMAT AND CONTENT The following illustrates the format and outlines the content for a typical Region I SALP Board Report.
Written material within parentheses ( ) is specific to the report, i.e., (name of.
11cen:;ee). Material within brackets [ ] is explanatory or directive in nature.
All other is standard "boilerplate" for a report.
-Tab A provides the guidance regarding the specific content of the " Analysis" for each functional area's performance analysis.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 E
l U.S. NUCLEAR REGULATORY COMMISSION REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (INSPECTION REPORT NUMBER) l l
(NAME OF LICENSEE) 1 (NAME OF FACILITY)
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(ASSESSMENT PERIOD)
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i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 TABLE OF CONTENTS PAGE l
I.
Introduction...
II.
Criteria.............................................................
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I I I. S umma ry o f Re s u l t s...................................................
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A.
Overall Summary.................................................
B.
Background......................................................
C.
Facility Performance Analysis Summary...........................
D.
Unplanned Shutdowns, Plant Trips, and Forced Outages........
IV.
Performance Analysis...............................................
A.
B.
C.
D.
Etc.
V.
Supporting Data and Summaries........................................
A.
Investigations and Allegations Review...........................
B.
Escalated Enforcement Actions.
C.
Licensee Conferences Held During Appraisal Period...............
D.
Confirmation of Action Letters..................................
E.
Other...
F.
Review of LERS, CDR, and 10 CFR 21 Reports by the Licensee...
G.
l.icensing Activities.........................................
TABLES Table I - Inspection Report Activities Table 2 - Inspection Hour Summary Table 3 - Enforcement Activity Table 4 - Licensee Event Reports El-3 t
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 I.
INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an inte-grated NRC staff effort to collect available observations and data on a peri-odic basis and to evaluate licensee performance based upon this information.
The SALP program is supplemental to normal regulatory processes used to ensure i
compliance with NRC rules and regulations. The SALP program is intended to l
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 perfct.- ice observations and data, and to assess licensee performance in accordance with the guidance in Chapter NRC 0516,
" Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety perfarm-ance at (name of facility) for the period (date) through (date).
The SALP Board was comprised of the following:
Chairman Members Other Attendees (non-voting)
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.c SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI.1440.1/0 II. CRITERIA Licensee performance is assessed in selected functional areas, depending upon whether the facility is in a construction, preoperational, or operational 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 lack of meaningful observations.
Special areas may be added to highlight significant observations.
l One or more of the following evaluation criteria were used to assess each functional area.
1.
M,anagement involvement and control in assuring quality.
2.
Approach to the resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Operational and Construction events (including response to, analyses of, and corrective actions for).
6.
Staffing (including management).
7.
Training and Qualification Effectiveness.
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
l Based upon the SALP Board assessment each functional area evaluated is classi-fied into one of three performance categories. The definitions of these per-formance categories are:
Category 1.
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.
Reduced NRC attention may be appropriate.
Category 2.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to opera-tional safety and construction quality is being achieved.
NRC attention should be maintained at normal levels.
Category 3.
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
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performance with respect to operational safety and construction quality is being achieved. Both NRC and licensee attention should be increased.
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.l LICENSEE PERFORMANCE RI 1440.1/0 I.
The SALP Board may determine to include an appraisal of the performance trend of a functional area. Normally, this performance trend is only 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. Improving (declining) trend is defined as: Licensee performance was determined to be improving (declining) near the close of the assessment period.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 l
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1 III.
SUMMARY
OF RESULTS d
A.
Overall Summary l
[The responsible DRP Branch Chief is tasked with developing an overall narrative-summary of results discussing significant licensee strengths and weaknesses per the Board's conclusions and directions. -- A draft pro-posed summary may be prepared in. advance of Board meeting; however, it-is recognized that the overall summary cannot be completed until the Board'sactionsarecompleted.]
l B.
Background-1.
Licensee Activities i
[ Provide an outline of major licensee activities, such as major l
. outages, power limitations, important license amendments, and sig-nificant modifications.]
2.
Inspection Activities
[ Provide a summary of major inspection activities in each functional area. This is not intended to be a summary of each routine'inspec-(
. tion performed, but rather a summary of major inspection activities.
Reference:
Table 1.]
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0
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C.
Facility Performance Analysis Summary Functional Area Last Period This Period Trend (Functional Area)
(Rating Last (Rating This (Trend if Period)
Period)
Assessed) 1 I
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I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 D.
Unplanned Shutdowns, Plant Trips, and Forced Outages Power Root Functional Date Level Description Cause Area
[1]
[2]
[3]
[1] Description to be a concise description of sequence of events lead-ing up to shutdown and the system / component / signal which initiated the plant trip; i.e., Manual, Low SGWL, Scram Discharge Volume High Level, etc.
[2] Root cause is either personnel, material, documentation (i.e., pro-cedural inadequacy) or design.
[3] The functional area responsible (i.e., operations, maintenance, surveillance, etc.), if determined.
NOTE: The root cause in this Table is the opinion of the SALP Board based on the inspector (s) description of the event and may, in certain instances, differ from the LER.
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b SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 IV.
PERFORMANCE ANALYSIS A.
[ Functional Area being discussed]
1.
Analysis
[The analysis of the licensee's performance in an area should in-clude 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 systems, adequacy of resources, training of personnel, etc., and the effectiveness of these efforts. Upon presentation of the analyses the attributes associated with the specified criteria are to be referred to for purposes of both completeness and to compare the conclusions reached with the attributes of each category. The attributes listed in, Table 1 are specifically oriented toward this and should be utilized. In no event, however, are the examples of licensee performance for specific attributes to be used as stand-alone as-sessments; 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
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safeguards information.
The analysis section is composed of three major subsections:
A brief summary of the previous evaluation including the rating and summary of the strengths and weaknesses.
A brief account of the inspection activity which occurred in this area.
A summary of the strengths, weaknesses, and other significant observations made by the NRC staff during the evaluation period.
A listing of the similar activities which comprise the functional areas to be included in Performance Analysis is contained in the following Tab A.]
2.
Conclusion
[ Provide the performance assessment (Category 1, 2, or 3) for each functional area considered.
Trend may be included.]
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' SYSTEMATIC ASSESSMENT OF.
. LICENSEE PERFORMANCE RI 1440.1/0 1.
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3.
Board Recommendations
[ Include any general or specific Board recommendations pertaining to either licensee management attention or NRC inspection activities in a functional area.
If appropriate, include a trend assessment, i.e., 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.]
NOTE: The Performance Analysis for each functional area should not exceed 2 pages.
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LICENSEE PERFORMANCE-RI 1440.1/0
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V.
SUPPORTING DATA AND SUMMARIES A.
Investigations and Allegations Review
[Pr:> vide a' summary of major investigative activities and-their results.]
8.
Escalated Enforcement Actions 1.
Civil Penalties [ Provide a summary].
2.
Orders (not only those relating to enforcement).
[ Provide.a sum-mary.]
C.
Licensee Conferences Held During Appraisal Period
[ Discuss conferences that dealt with regulatory performance or enforce-ment.]
D.
Confirmation of Action Letters
[ Provide a summary.]
E.
Other
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[ Discuss any other issues at the discretion of the SALP Board ]
F.
Review of Licensee Event Reports, Construction Deficiency Reports, and 10 CFR 21 Reports Submitted by the Licensee
[ Provide a brief summary of significant findings and trerids resulting from a review of these reports.
If this information is contained in another section of the report, this item may be omitted.]
G.
Licensing Activities
[ Provide a summary of significant occurrences in each of the following 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 pro-grams.]
i 1.
NRR/ Licensee Meetings [ Discuss meetings that dealt with significant i
licensingissues].
2.
CommissionMeetings[Discussmeetingsthatdealtwithsignificant licensingissues].
3.
NRC Site Visits [ Discuss visits that dealt with significant licens-ingissues].
4.
S:hedular Extensions Granted 5.
Reliefs Granted j
6.
Exemptions Granted i
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1 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 7.
Emergency Actions Granted i
8.
License Amendments Issued l
9.
Orders Issued 10.
Issues Pending l
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l SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 144'.1/0 TABLE 1 1
I INSPECTION REPORT ACi
'T*ES Report No.
Inspection Hours Area (s) Inspected i
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t SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 TABLE 2 INSPECTION HOUR
SUMMARY
HOURS Actual Annualized Percent 1.
Plant Operations 2.
Radiological Controls 3.
Maintenance 4.
Surveillance 5.
Security and Safeguards 7.
Outages 8.
Assurance of Quality 9.
Licensing Activities 10.
Engineering Support
- 11. Training and Qualification Effectiveness TOTAL (NOTE:
Example for typical operating plant.)
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SYSTEMATIC ASSESSMENT OF
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' LICENSEE PERFORMANCE-RI 1440.1/0 3.-
TABLE 3 ENFORCEMENT ACTIVITY A '.
Violations Versus Functional Area By Severity Level Functional No. of Violations in Each Severity Level
' Area V
IV III II I
Total 1.
Plant Operations i
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Radiological Controls 3.
Maintenance 4.
Surveillance 5.
Security and Safeguards 7.
Outages.
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Assurance of Quality 9.
Licensing Activities
- 10. Engineering Support l
- 11. Training and Qualification l
TOTAL (NOTE: Example for typical operating plant.)
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(TABLE 3 CONTINUED)
B.
Summary Inspection Severity Functional Brief Number Requirements Level Area Description
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. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0
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TABLE 4 LICENSEE EVENT REPORTS A.
LER By Functional Area Number By Cause Code Functional Area A
B C
0 E
X 1.
Plant Operations 2.
Radiological Controls 3.
Maintenance 4.
Surveillance 5.
Security and Safeguards 7.
Outage 8.
Licensing Activities TOTAL (NOTE: Example for typical operating plant.)
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0
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(TABLE'4 CONTINUED)
B.
LER Synopsis LER Number Summary Cause
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SYSTEMATIC ASSESSMENT OF l
LICENSEE PERFORMANCE RI 1440.1/0 h
1 TAB A CONTENT OF FUNCTIONAL AREA ANALYSES BY FUNCTIONAL AREA 1.
Operating phase Reactors A.
Plant Operations Consists chiefly of the activities of the licensee's operational staff (e.g., licensed operators, shift technical advisors, and auxiliary opera-tors).
It is intended to be limited to operating activities such as:
plant startup, power operation, plant shutdown, and system lineups. Thus, it includes activities such as reading and logging plant conditions; re-sponding to off normal conditions; manipulating the reactor and auxiliary controls; plant wide housekeeping; and control room professionalism, Note: See E. below.
B.
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.
(1) Occupational Radiation Safety - includes controls by licensees and contractors for occupational radiation protection, radioactive ma-terials.and contamination controls, radiological surveys and moni-toring, and ALARA program.
(2) Radioactive Waste Management - includes processing and onsite stor-age of gaseous, liquid, and solid wastes.
(3) 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 NRC's confirmatory measurements program.
(4) Transportation of Radioactive Materials - includes procurement and selection of packages, preparation for shipment, selection and con-trol of s<1ppers delivery to carriers, receipt / acceptance of ship-ments by receiving facility, periodic maintenance of packagings and, for shipment of spent fuel, point of origin safeguards activities.
(5) Water Chemistry Controls - includes primary and secondary systems affecting plant water chemistry, water chemistry control program, and progran: implementation; chemistry facilities; equipment and procedures; and chemical analysis quality assurance.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0
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(Tab A Continued)
C.
Maintenance Includes all licensee and contractor activities associated with preven-tive or corrective maintenance of instrumentation and control equipment, I
and mechanical and electrical systems.
D.
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 test of pumps and valves, and all other inservice inspection activities.
E.
Fire Protection Includes routine housekeeping (combustibles, etc.) and fire protection /
prevention program activities.
Thus, it includes the storage of combust-ible material; fire brigade staffing and training; fire suppression sys-tem maintenance and operation; and those fire protection features pro-vided for structures, systems, and components important to safe shutdown.
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Note:
This area is not normally treated as a separate functional area unless there is substantial inspection effort in the area or an overall evaluation of the program during the assessment period.
The various elements of this functional area, e.g.,
operations, maintenance, will normally be addressed in the applicable functional area.
F.
Emergency Preparedness Includes activities relating to the implementation of the emergency plan and implementing procedures. Thus, it includes such activities as lic-ensee's performance during exercises which test the licensee, state, and local emergency plans; plan administration and implementation; notifica-tion; communications; facilities and equipment; staffing; training; as-sessment; emergency classification; medical treatment; radiological ex-posure control; recovery; protective actions; and interfaces with onsite and office emergency response organizations.
G.
Security and Safeguards Includes all activities whose purpose is to ensure the security of the plant and safeguarding of special nuclear material.
Specifically it in-cludes all aspects of the licensee's security program (e.g., access con-trol, security checks, safeguards). This functional area should also address licensee activities relative to fitness for duty.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 i
(Tab A Continued)
H.
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 i
generator tube repairs or primary loop piping replacement), and all post-i outage startup testing of systems prior to return to service. Design-related activities are also included in this functional area.
I.
Assurance of Quality Includes all management control, verification and oversight activities which affect or assure the quality of plant activities, structures, sys-tems, and components. This area may be viewed as a comprehensive manage-ment system for controlling the quality of work performed as well as the quality of verification activities that confirm that the work was per-formed 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.
Emphasis should be given to evaluating the effectiveness and involvement of management in establishing and assuring the effective implementation
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of the quality assurance program along with evaluating the history of licensee performance in the key areas of: committee activities, design and procurement control, control of design change processes, inspections, audits, corrective action systems, and records. The primary purpose of this section is to assess the effectiveness of the licensee's program for identifying and correcting problems.
J.
Licensing Activities Includes all activities supporting the NRC review of amendment requests, exemption requests, relief reports, response to generic letters and bul-letins, and TMI items classified as: Multi-Plant Actions, Plant Specific Actions, and TMI (NUREG-0737) Actions.
In addition, it includes an as-sessment of licensee activities related to design and safety issues. It also includes NRC meetings that dealt with significant licensing issues.
K.
Engineering Support Inclues all activities of an engineering / technical nature beyond those provided by the operating organization professional-technical personnel in support of operating activities. This may include review and audit operations of the nuclear plant.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 (Tab A Continued)
L.
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 j
covered by the Commission Policy Statement on Training and Qualification, this functional area includes all activities relating to the effective-ness of the training / retraining and qualifications program conducted by the licensee's staff and contractors for these categories in facility training.
(a) Non-licensed operators (b) Control room operators (c) Senior control room operators /shif t supervisors (d) Shift 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 Note:
Attributes of this topic should be discussed in each functional
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area; this functionat area is used to provide a synopsis of the effectiveness of the training and qualifications programs.
M.
Others (As needed. An example of this is where a licensee has exhibited a weak-ness in one component of a functional area, such as the design component of the outages functional area, and significant inspection activity has occurred during the period.)
2.
Construction Phase Reactors A.
Soils and Foundations Includes all soil and foundation activities related to the construction of the ultimate heat sink and safety-related structures.
Specifically, this covers, as applicable, subgrade investigation and preparation, fill materials and compaction, embankments, foundations and associated labora-tory testing, and instrumentation and monitoring systems.
B.
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 struc-(
tural concrete (e.g., reinforcing steel; concrete batching, delivery, El-23
.i SYSTEMATTC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 (Tab A Continued) placement, in process testing, and curing; liner place erection and fab-rication; and containment post-tensioning), structural steel used in safety-related structures (welded and bolted), and major steel equipment supports (for reactor vessel, reactor coolant pumps, steam generators, pressurizer, polar crane, tanks, heat exchangers, etc.).
C.
Piping Systems and Supports Includes those safety-related piping systems described in 10 CFR 50.2(v) and R.G. 1.26, quality groups A, B, and C.
It is intended to be limited to the primary pressure boundary and other safety-related water, steam and radioactive waste containment piping systems.
It includes those quality checks necessary to ensure compliance with the applicable codes and other requirements specified in the SAR for these systems.
The prim-ary inspection emphasis in this area is on piping systems and their sup-ports / restraints.
D.
Safety-Related Components - Mechanical Covers mechanical components such as pressure vessels, pumps, and valves located in, and attached to, the piping systems described _in C above.
r The primary emphasis here is on components rather than piping.
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E.
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.
F.
Electrical Equipment and Cables Includes safety-related electrical components, cables, and associated items used in the electrical systems of the plant, such as: motors, transformers, batteries, emergency diesel generators, motor control cen-ters, switchgear, electric raceways, cable (power, control, and instru-ment), circuit breakers, relays, and other interrupting and protective devices.
G.
Instrumentation Covers safety-related instrument components and systems that are designed to measure, transmit, display, record and/or control various plant vari-l ables and conditions. The Reactor Protection System and the Engineered
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Safety Features Actuation System are two plant systems utilizing such devices as: sensors, transmitters, signal conditioners, controllers and
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other actuating devices, recorders, alarms, logic devices, instrument i
air supplies, racks, and panels.
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. SYSTEMATIC AS$ESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0
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(Tab A Continued)
H.
Assurance of Quality Includes all management control, verification, and oversight activities which affect or assure the quality of plant structures, systems, and com-ponents.
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 cor-rectly. 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 Im-plementation of the quality assurance program along with evaluating the history of licensee / contractor performance in the key areas of: quality assurance program, design and procurement control, control of construc-tion processes, inspections, audits, corrective action systems, and records.
1.
Licensing Activities f.
Includes all activities supporting the NRC review of the application for
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and the issuance of the Construction Permit and 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, J.
Engineering Support See 1.K above.
K.
Others (As needed.)
3.
preoperational phase Reactors A.
Preoperational Testing Covers the preparation, conduct, and evaluation of test rasults for pre-operational tests performed by or under the direction of the licensee's staff to demonstrate the proper functioning and conformance to design requirements of components, systems, and structures.
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SYSTEMATlc ASSESSMEdT CF LICENSEE PERFORMANCE RI 1440.1/0
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B, Others'(As Needed) l For reactors in the preoperationai phase, functional areas from the listing for either operating phase reactors or construction phase reac-tors should be selected as appropriate.
4.
Startup Phase Reactors A.
Startup Testing Covers the preparation, conduct, and. evaluation of test results for testing conducted following the issuance of the operating license.
It starts with initial fuel loading and precritical tests, and continues until the plant reaches commercial operating status at or near its lic-ensed power rating.
B.
Others (As Needed)
For reactors in the startup phase, functional areas from the listing for i
operating phase reactors should be used.
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f C.
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r SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0
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ENCLOSURE 2 THE SALP BOARD 1.0 Purpose.
To prescribe the composition and functional responsibilities of the SALP Board.
2.0 Composition. An individual SALP Board shall be constituted for the assessment of each licensee or plant from among the following:
Chairman:
Director or Deputy Director, DRP (or Director with Project responsibility)
Voting Members:
Director or Deputy Director, DRS Director, DRSS Management Representative, NRR Cognizant Chief, Projects Branch, DRP Chief, Operations Branch, DRS Chief, Engineering Branch, DRS Chief, Emergency Preparedness and Radiological Protection Branch, DRSS Chief, Nuclear Materials Safety and Safeguards Branch, r
DRSS lk Cognizant Chief, Reactor Projects Section, DRP Senior Resident Inspector, DRP Licensing Project Manager, NRR A quorum shall cons 1st of five members including the chairman and four voting members; however, no person in an acting capacity (i.e., not detailed) shall be a voting member unless otherwise qualified. No division should constitute a majority.
The composition of the SALP Board shall be promulgated by Regional announce-ment approximately 20 days before the meeting date.
3.0 Functions The SALP Board shall:
Review and discuss the draft SALP Board Assessment Report.
Ensure that sufficient information has been orovided in each functional area analysis to form a conclusion regarding licensee performance or conversely, to confirm that sufficient information is not available to support a con-clusion regarding licensee performance.
As appropriate, request the presence of staff members to discuss the bases of findings and recommendations.
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e
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SYSTEMATfC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 Rate licensee performance in each functional area after considering the evaluation criteria with their associated attributes as listed in 4.0 below.. Ratings shall be determined by majority vote.
After rating of all functional areas, provide a summary statement (SALP Board Report,Section III) on the licensee's overall performance empha-sizing-significant strengths or weaknesses. Areas that the Board con-siders to require additional effort tn' achieve improved performance shall be addressed.
Recommend changes to the inspection program emphasis, as necessary, and recommend the duration of the subsequent SALP assessment period.
4.0 EVALUATION CRITERIA The assessment of licensee performance is implemented through the use of six i
or seven evaluation criteria.
The criteria provide standard guidance that shall be applied to each functional area for the categorization of licensee i
performance.
i To provide consistent evaluation of licensee performance, several attributes associated with each criterion are listed to describe the characteristics applicable to the three categories.
The six criteria discussed in Chapter NRC-0516-045 are listed in Table 1 with their associated attributes. These form the guidance which aides in under-standing and evaluating licensee performance by identifying the causes and i
factors appropriate for categorization.
It is not intended that consideration i
of these. attributes influence established programs of the agency.
For example, it is not intended that specific inspections be performed to ; valuate attri-l butes.
It is expected that during the implementation of established programs, i
many-of the attributes should assist the staff in their observation of licen-see performance during routine activities.
All of the attributes of the evaluation criteria are not necessarily applic-able. In some instances, the observed performance within a functional area may be insufficient to allow consideration in the evaluation. However, mat-ters such as management involvement and staffing are criteria of each func-tional area and should be considered in the evaluation of the functional areas.
j 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 j
weighed. If information is scarce or nonexistent, a decision regarding the performance category as it related to an attribute should not be forced.
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i SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 7
TABLE 1 EVALUATION CRITERIA WITH ATTRIBUTES FOR f
ASSESSMENT OF LICENSEE PERFORMANCE j
i 1.
Manac,ement Involvement in Assuring Quality Category 1 Category 2 Category 3 l
Consistent evidence of prior Evidence of prior planning Little evidence of prior planning and assignment of and assignment of priorities; planning and assignment priorities; well stated, con-stated, defined procedures of priorities; poorly controlled and explicit pro-for control of activities, stated or ill understood cedures for control of acti-procedures for control vities.
of activities.
Well stated, disseminated, Adequately stated and under-Poorly stated, poorly and understandable policies.
stood policies.
understood or nonex-istent policies.
Decisionmaking consistently Decisionmaking usually at a Decisionmaking seldom at a level that ensures ade-level that ensures adequate at a level that ensures quate management review.
management review, adequate management review.
Corporate management fre-Corporate management usually Corporate management quently involved in site ac-involved in site activities, seldam involved in site tivities.
activities.
Reviews timely, thorough and Reviews generally timely, Reviews not timely, technically sound.
thorough and technically thorough or technically sound.
sound.
Records complete, well main-Records generally complete, Records not complete, tained, and available.
well maintained, and avail-not well maintained, able.
or unavailable.
Procedures And policies Procedures and policies Procedures and policies strictly adhered to.
rarely violtted, occasionally violated.
Corrective action is effec-Corrective action is usually Corrective action is tive, as indicated by lack taken but may not be effec-not timely or effective of repetition.
tive at correcting the root and generally addresses cause of the proolem, as in-symptoms rather than dicated by occasional repe-root causes, events tition.
are repetitive.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMAt;CE RI 1440.1/0 2.
Approach to the Resolution of Technical Issues from a Safety Standpoint Category 1 Category 2 Category 3 Clear understanding of Understanding of issues Understanding of issues issues demonstrated.
generally apparent, frequently lacking.
Conservatism routinely ex-Conservatism generally ex-Meets minimum require-hibited when potential for hibited.
ments.
j safety significance exists.
Technically sound and Viable and generally sound Often viable approaches; thorough approaches in and thorough approaches.
but lacking in thorough-almost all cases.
ness or depth.
Timely resolutions in Generally timely resolu-Resolutions often de-almost all cases.
tions.
layed.
3.
Responsiveness to NRC Initiatives Category 1 Category 2 Category 3 Meets deadlines.
Generally timely responses.
Frequently requires extensions of time.
Timely resolution of issues.
Few longstanding regulatory Longstanding regulatory issues attributable to issues attributable licensee.
to licensee.
Technically sour.d and Viable and generally sound Often viable responses, thorough responses in almost and thorough responses.
but lacking in all cases.
thoroughness or depth.
Acceptaale resolutions pro-Acceptable resolutions Considerable NRC effort posed initially in most generally proposed.
or repeated submittals i
cases.
needed to obtain ac-ceptable resolution.
4.
Enforcement Histo *y Category 1 Category 2 Category 3 Majcr violations are rare Major violations are rare and Multiple major viola-and are not indicative of may indicate minor program-tions or programmatic of programmatic breakdown.
matic breakdown.
breakdown indicated.
i Minor violations are not re-Multiple minor violations or Minor violations are petitive and not indicative minor programmatic breakdown repetitive and indica-I of programmatic breakdown.
indicated.
tive of programmatic breakdown.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 4.
(Continued)
Corrective action is prompt
. Corrective action is timely Corrective action is and effective.
and effective in most cases.
delayed or not effective.
5.
Operational and Construction Events Category 1 Category 2 Category 3 Few significant operational Occasional significant Frequent significant or construction events, at-operational or construction operational er con-tributable to causes under events, attributable to struction events, at-the licensee's control, have causes under the licensee's tributable to causes occurred that are relevant control, have occurred that under the licensee's to this functional area.
are relevant to this func-control, have occurred tional area, that are relevant to this functional area.
Events are promptly and com-Events are reported in a Event reporting is pletely reported.
timely manner, some informa-frequently late or tion may be lacking.
incomplete.
Events are properly identi-Events are accurately iden-Events are poorly iden-(r' fied and analyzed.
tified, some analyses are tified or analyses are marginal.
marginal, events are associated with pro-grammatic weaknesses.
6.
Staffing (Including Management)
Category 1 Category 2 Category 3 Positions are identified, Key positions are identified, Positions are poorly authorities and responsi-and responsibilities are de-identified, or authori-bilities are well defined,
- defined, ties are ill defined.
Vacant key positions are Key positions are usually Key positions are left filled on a priority basis.
filled in a reasonable time, vacant for extended periods of time.
Expertise is available with-Expertise is usually avail-Very little expertise in the staff; rarely needs able within the staff; makes within the staff; ex-outside consultants, staff-appropriate use of consult-cessive reliance on ing is ample as indicated by ants; staffing is adequate, consultants; staffing control over backlog and occasional difficulties with is weak or minimal as overtime.
backlog or overtime, indicated by excessive backlog or overtime.
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 6.
(Continued)
Experience levels for manage-Experience levels for manage-Experience levels for ment and operations personnel ment and operations personnel management and opera-exceed commitments made by meet commitments made by lic-tions personnel are licensee at time of licens-ensee at time of licensing.
below commitments made ing.
by licensee at time 1
of licensing.
7..
Training and Qualification Effectiveness (See Note Below)
Category 1 Category 2 Category 3 Training and qualification Training and qualification Training and qualifi-program makes a positive con program contributes to an cation program is found tribution, commensurate with adequate understanding of to be the major con-procedures and staffing, to work and fair adherence to tributing factor to understanding of work and procedures with a modest poor understanding of adherence to procedures with number of personnel errors, work, as indicated by few personnel errors, numerous procedure violations or personnel errors.
Training program is well de-A defined program is imple-Program may-be either
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dedicated resources and a of the staff.
or ineffectively fined and implemented with mented for a large portion lacking, poorly defined.
means for feedback of ex-perience; program is applied applied for a signifi-to nearly all staff.
cant segment of the staff.
Inadequate training could Inadequate training could Inadequate training rarely be traced as a root occasionally be traced as a could regularly be cause of major or minor root cause of major or minor traced as a root cause events or problems occurring events or problems occurring of major or minor during the rating period.
during the rating period.
events or problems occurring during the rating period.
NOTE:
The elements of this criteria are to be applied in the assessment of a functional area which addresses training and qualification effectiveness as a subset of the functional area's overall assessment, e.g., if the training and qualification of maintenance personnel is considered in the assessment of the Maintenance functional area, Criterion 7 should be applied in that assessment.
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SYSTEMATIC ASSESSMENT OF 1
LICENSEE PERFORMANCE RI 1440.1/0 t
.s ENCLOSURE 3 LICENSEE MANAGEMENT MEETING l
- 1. 0' General It is the policy of the Regional Administrator to meet with licensee manage-
')
ment in order to discuss the assessment of the licensee's performance.
2.0 Meeting Preparation Notification of the meeting should be made by the Region to the licensee, the cognizant Regional personnel, the resident inspectors at the involved facili-ties, the NRR Project Managers for the involved facilities, and cognizant NRC managers.
The licensee should be encouraged to have the following management represen-tatives participate in the meeting.
a.
Senior corporate management representative.
b.
Management officials responsible for the major functions wherein problem
)
areas have been identified (e.g., health physics, security, engineering).
((.
c.
Site Manager.
3.0 Meeting With Licensee The meeting should be conducted within 70 days of the end of the assessment l
period.
NRC representatives for this meeting should include the following:
a.
Either the Regional Administrator, Deputy Administrator, or a Division Director.
b.
Responsib'ie Regional Division Director (s), Branch Chiefs, or Section Chiefs, as appropriate.
c.
NRR Project Manager and designated NRR manager.
ll d.
Resident Inspector and/or assigned inspectors.
e.
Public Affairs Officer, when media interest is anticipated.
The Regional Administrator, Deputy Administrator, or Division Director will chair the meeting and discussions of the adequacy of the licensee's management controls.
These meetings are intended to provide a forum for candid discus-l(~
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.1' SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0
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sion of issues relating to the licensee's performance.
Those aspects of the licensee's operation 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 re-port if no meeting is held.
Only written comments from the licensee must be addressed by the Regional Administrator.
SALP management meetings with the licensee should be conducted as open meet-
'ings, with the exception of those portions of the meetings that involve dis-cussion of the matters not required to be mandatorily placed in the public-domain pursuant to 10 CFR'2.790 or 10 CFR 73.21, which must be closed. Mem-bers of the public should be treated as observers. Adequate notification of the SALP meeting can be accomplished by PDR distribution of the letter to the licensee which schedules the meeting, with copies to the service list for the appropriate docket.
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Se SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE RI 1440.1/0 ENCLOSURE 4 SALP BOARD REPORT AMENDMENTS 1.0 Purpose To prescribe the procedure for amending a final SALP Board Report.
2.0 Background
The SALP Board Report is considered final upon approval by the Board, signa-ture of the letter of transmittal by the Regional Administrator, and forward-ing to the licensee. The report may be amended, however, following due con-sideration of material presented by the licensee in the course of the manage-ment meeting with the licensee or in writing in response to the report.
3.0 Procedure 3.1 Report Amendment Immediately following the report number on the cover sheet, add (" Amended Report").
Each page of the original report affected by the amendment shall have
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a single diagonal line drawn across it and shall be annotated, "See amended page following" The amended page number shall have a letter "A" (or "B", "C", etc., if more than one page is involved in the page change).
The new pages shall be included in the report immediately fol-lowing the original which had been annotated as being amended.
3.2 Transmittal A new letter of transmittal shall be prepared which includes a precis l
of amendments and the rationale therefor and a summary of the results l
of the meeting with licensee management.
The new letter of transmittal shall include as enclosures:
1.
Amended SALP Board Report 2.
Copy of original letter of transmittal 3.
Copy of response (s) from licensee 4.
List of attendees at management meeting The new letter of transmittal shall be signed by the Regional Admini-strator and should normally be forwarded within ten days of receipt of response from the licensee.
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