NG-95-2723, Comment Supporting Revised NRC SALP Program

Comment Supporting Revised NRC SALP Program

ML20092C803
Person / Time
Site:	Duane Arnold
Issue date:	09/05/1995
From:	Keith Young IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR39193, RULE-PR-50 60FR39193-00023, 60FR39193-23, NG-95-2723, NUDOCS 9509130142
Download: ML20092C803 (5)

Text

\Q Duane Amold Energy Center 3277 DAEC Road y

Pao, IA 52324

., Telephone 319 8517611

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8/l/4S September 5,1995 NG-95-2723 Chief, Rules Review and Directives Branch Division of Freedom ofInfonnation and Publication Services Office of Administration Mail Stop T-6D-59 U.S. Nuclear Regulatory Com. mission Washington, DC 20555-0001

Subject:

Duane Amold Energy Center (DAEC)

Docket No: 50-331 Op. License No: DPR-49 Request for Public Comment on SALP Process

References:

Federal Register Notice Vol. 60, No.147.

File: A-100

Dear Sir:

The following comments are provided by IES Utilities Inc. in response to the request for comments on the NRC Systematic Assessment of Licensee Performance (SALP) per the referenced Federal Register Notice.

Al. Are the current four functional areas (operations, maintenance, engineering, and plant support) an improvement compared to the previous seven functional areas?

Yes. The four functional areas are an improvement over the previous seven functional areas in that they provide a better focus on plant performance and operation.

Additionally, the recent focus of routine Resident inspection Reports on the same four functional areas provides more consistency between the normal inspection and SALP processes. Ilowever, assigning individual ratings for the functional areas can also have adverse consequences in that it encourages development of" functional silos" in which each individual department emphasizes its performance rather than the performance of the plant as a whole. The NRC staff should evaluate the benefits of an integrated plant rating.

9509130142 950905 PDR ADOCK 05000331 G PDR l An IES Industnes Company l

NG-95-2723

- 9/5/95

Page 2 of 5 A2. Are the plant support functional areas messages clear in characterizing individual elements (radiological controls, emergency preparedness, security, fire protection,

chemistry, and housekeeping)?

. The most recent SALP report for the DAEC clearly characterized the individual elements of the

Plant Support area.

A3. Are additionalimprovements needed for the designation of functional areas? What types ofimprovements?

{ See Al above.

i l Hl. Did increased NRC management involvement in the SALP program result in

program improvements and improved communication with licensee management?

l IES Utilities already has clear and open communications with NRC personnel at all levels. The l SALP cycle visit to the plant by the senior NRC Regional Management is worthwhile in that it

] permits senior NRC personnel to personally assess the plant and the people, and communicate j expectations to all levels of the utility management.

f H2. Did the SALP program changes result in better licensee and public understanding j of the SALP results?

j I believe that the utilities understood the SALP results both before and after program changes; so changes did not enhance utility understanding.

4 The public does not understand SALP results. What they understand is the image that is created in their minds by listening to the tone of the SALP dialogue if they attend the meeting.

i Otherwise, they believe what they read in the newspapers. Most journalists listen for particular i " sound bites" uttered by utility or NRC management, either during or after the meeting. Program 2

changes have little or no affect on public understanding.

H3. Did increased involvement of the regional administrator or deputy at the SALP

meeting result in improved communication with licensee management? ,

i The SALP meeting is a formal meeting in a public setting. The quality of the communications ,

are established more by the setting than by the degree of participation by any single individual.

t H4. Was the change in SALP presentation meeting format - from a presentation to more of a discussion - effective in improving communication with licensee management?

4 Open and effective communications between a utility and the NRC are the result oflong term efforts to develop an effective working relationship. The discussions at the SALP meeting are more formal and are based on an already issued and approved SALP report and therefore, do not ,

substantially add to improving communications with licensee management.

i

NG-95-2723

. 9/5/95 Page 3 of 5 B5. Arc additional improvements needed in the areas of communications with licensee management and licensee and public understanding of SALP results? What types ofimprovements?

Yes. NRC routine and functional area inspection results are previewed before finalization through exit meetings which provide the opportunity for frank and open discussions of results and findings. Exit meetings clarify many issues. The SALP process could provide a similar mechanism for utility feedback on assessment results prior to issuance of the final report.

Cl-3. No Comments DI. Are the new, shorter SALP reports more effective in communicating the results of the NRC's assessment of safety performance than the previous, more lengthy reports?

Yes. The new SALP report format and level of detail are effective in communicating the results of the NRC's assessment but the link between identified weaknesses or concerns and safety performance needs to be better communicated. Additionally, issues of minor safety significance (as documented in previous inspection reports) are still included.

D2. Are SALP reports appropriately focused on safety issues and do they deliver a clear message?

See D1 above.

D3. Do SALP reports provide a balanced assessment oflicensee safety performance (and are positive aspects oflicensee safety performance appropriately considered)?

The most recent DAEC SALP report significantly improved in this area in that it provided a balanced view of DAEC performance by including examples of positive performance as well as areas in need ofimprovement. Traditionally, SALP reports have concentrated on the negative aspects of performance.

D4. Do SALP reports consistently focus on the last six months of performance? Is this practice appropriate?

Yes. The most recent DAEC SALP report focused on the last six months. Focusing SALP reports on the last six months of performance has both positive and negative aspect The last six ,

months reflect a licensee's recent performance trend and as such, ensures the SALP report emphasizes current performance. Ilowever, individual events (violations, equipment problems, etc.) that occur in this time period can have a disproportionately large effect on the SALP report which is not consistent with overall performance of the plant during an 18 month period. ,

Additionally, an emphasis on the last six months ollen results in the scheduling of numerous l inspections during this period which can put a large resource burden on utilities to support the inspections. l l

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Page 4 of 5 l l

1 D5. Is the level of detailin the SALP report appropriate? j See D1 above.

D6. Are SALP report conclusions well-supported by documented facts?

While shorter SALP reports contain less supporting information than the previous SALP format, l most of the observations and conclusions are well supported or documented in more detail in l routine Resident and Functional Area inspection Reports. On rare occasions, a report conclusion  ;

may be less than well supported.

D7. Are SALP report cover letter messages consistent with the associated SALP reports messages?

The SALP report cover letter message is usually consistent with the body of the SALP report.

Ilowever, generalizations in the cover letter are sometimes not well supported in the body of the report.

D8. Arc li:rnsee self-assessment efforts adequately recognized in the SALP report and  !

cover letter? t DAEC self assessment efforts were appropriately recognized in the most recent SALP report.

D9. Are additionalimprovements needed in the SALP reports? What types of improvements?

The relationship between the S ALP process and the recently implemented Integrated Performance Assessment Process (IPAP)is unclear. The processes seem duplicative. The purpose and format of the SALP process should be re-evaluated as the IPAP is implemented.

l

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NG-95-2723 9/5/95 Page5 of5 Please contact this office at (319) 851-7307, if you have any questions on the above.

Sine ly, c

Keith D. Young Manager, Nuclear Licensing JIT/PMil/mbm c:\lic\bridget\ng952723.co ec: J. Franz L. Liu

11. Fisher D. Mineck G. Kelly (NRC-NRR)

11. Miller (Region III)

NRC Resident Office Docu