NRC-92-0120, Comment on Proposed Changes to NRC SALP Program.Numerical Rating Sys Detracts from Communication Process

Comment on Proposed Changes to NRC SALP Program.Numerical Rating Sys Detracts from Communication Process

ML20115E189
Person / Time
Site:	Fermi
Issue date:	10/09/1992
From:	DETROIT EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
CON-NRC-92-0120, CON-NRC-92-120, FRN-57FR39249 57FR39249, NUDOCS 9210220041
Download: ML20115E189 (2)

Text

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92 0C115 NO A0 October 9, 1992 -

NRC-92-0120 Chief, ' Rules and Dir ectives Review Branch U. S. Nuclear Regulatory Commission Washington, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 '

NRC License No. NPF-43

2) NRC Meeting Notice, " Systematic Assessment of Licensee Performance (SALP) Program," 57FR 39249

Subject:

Detroit Edison Comments Concerning- the Systematic Assessment of Licensee, Performapce_ Program _ (f/fyn,39249)

Detroit Edison appreciates the opportunity to comment oc the picposed changes to the NRC Systematic Assessment of Licensee Perforrance

-(SALP) program as requested by Reference 2.

Detroit Edison recognizes the need fot the NRC to have a menns to assess the performance of the licensees under their jurisdiction, and to convey the resulta of that assessment to the licensees. In addition, the SALP process and the subsequent reports are gaining increasing public attention.

Detroit Edison also believes that the numerical rating system detracts from the communication process. Many users focus on the ratings to the exclusion of the narrat .ve details, which contain the mot e precise appraisal of performance. In addition, numerical ratings invite compar2 sons between licensees and averaging of scores over the functional areas. Such practices do not have real meaning but only tend to distort the report's intended message.

In order for the process to be effective, the terms used in the SAll

, ratings must be clearly defined. Their meaning,' particularly in the '

'- evaluation criterio portion of the NRC's SALP guidance. should be L clear. Evaluation criteria should be defined in terms of ability to j meet regulatory requirements and licensee performance should bc: judged l on specific examples.

The proposed functional area of " Plant Support" is too general, particularly if nturerical ratings are applied. . A. single rating when applied to these diverse functions will convey little information.

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USNRC October 9, 1992 NRC-92-0120 Paie 2 -

Ferformance will often vary significantly within the grouped functions, a single rating will not adequately reflect this.

In particular, we believe the functional area of Radiological Controls should not be included in the " Plant Support" area. Such a grouping does not recognize the unique focus of the Radiological Controls area in controlling and reducing worker radiation exposure. An outstanding Radiological Controls program is in and by itself a significant Eoal for a licensen. We believe licensee perf ormance in neeting this goal should be separately assessed.

Care must be taken when a specific program is mentioned in the description of a functional area. For example, the Decign Basis Reconstitution (DBR) program is specifically identified in the Engineering functional area. Such identification will tend to focus industry resources toward establishing such programs. Whether this is ,

appropriat e for a plant depends on the plant's performance in meeting the associattd functional requireme nts. A DBR program may not be needed if a plant adequately resolves design basis issues in a timely manner. In general, we believe performance in meeting functional requirements shou]d be assessed and not the adequacy of a terricular program.

Detroit Edison believes the SALP process is an inportant communication +

tool and welcomes the opportunity to participate in its development.

If ynu have any questions regarding our comn.ents, please contact Mr.

A. Cecil Settles at (313) 586-4211.

Sincerely,

/

cc: T. G. Colburn l A. B. Davis L M. P. Phillips S. Stasek

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