NRC Generic Letter 1992-05
Spi RE(44
0 UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555 September 4, 1992 TO: ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR
NUCLEAR POWER REACTORS
SUBJECT: NRC WORKSHOP ON THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
(SALP) PROGRAM - GENERIC LETTER 92-05 The U.S. Nuclear Regulatory Commission (NRC) is announcing its plans to conduct a workshop on the SALP Program on September 29, 1992. The workshop will be held from 9:00 a.m. to 5:00 p.m. at the Holiday Inn Crowne Plaza, 1750
Rockville Pike, Rockville, Maryland 20850, telephone (301) 468-1100.
The NRC SALP Program is the Agency's integrated effort to collect and evaluate available agency insights and information in a structured manner to assess and better understand licensee performance. The NRC is interested in obtaining comments from the public and industry on its proposed changes to the SALP
Program. A copy of the draft Management Directive 8.6, "Systematic Assessment of Licensee Performance," is enclosed for information only. Once approved, Management Directive 8.6 will replace the current program guidance contained in Manual Chapter 0516, "Systematic Assessment of Licensee Performance." The staff will consider comments received during this workshop, and those received separately, in preparing its final recommendations to the Commission for changes to the SALP Program. The NRC published a notice of this workshop in the Federal Reqister on August 28, 1992.
The workshop will consist of a plenary session, break-out sessions, and a summary session. During the plenary session, NRC representatives will discuss proposed changes to the SALP Program. This will be followed by break-out sessions in which attendees may ask questions about the SALP Program and make comments or suggestions for improving the SALP Program. The workshop will conclude with a session to summarize the issues discussed in each of the break-out sessions.
Persons planning to attend the workshop should complete a copy of the enclosed registration form and send it to Mr. Cornelius Holden, M/S 10-A-19, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.
Interested parties unable to attend this workshop may submit written comments by September 29, 1992. Comments received after this date will be considered if it is practical to do so, but the Commission can ensure consideration only for comments received on or before this date. Submit written comments to the Chief, Rules and Directives Review Branch, U.S. Nuclear Regulatory Commission, Washington D.C. 20555.
9209040202
- 2 - September 4. 1992 This generic letter contains no information collection requirements and therefore is not subject to the requirements of the Paperwork Reduction Act of
1980 (44 U.S.C. 3501 et seq.).
Please contact Cornelius Holden (301-504-1037) if you have any questions about this matter. No specific licensee actions are required.
Sincerely, mes G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:
As stated
REGISTRATION FORM
UNITED STATES NUCLEAR REGULATORY COMMISSION
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE PROGRAM
HOLIDAY INN CROWNE PLAZA HOTEL
SEPTEMBER 29, 1992 NAME
TITLE
COMPANY/ORGANIZATION.
ADDRESS
TELEPHONE NUMBER
SUGGESTED TOPICS RELATED TO THE SALP PROGRAM TO BE CONSIDERED FOR DISCUSSION:
Send registration form to: Cornelius HQlden M/S 10 A 19 Office of Nuclear Reactor Regulation- U. S. Nuclear RegulatoryCommission Washington, D.C. 20555
LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of Letter No. Subject Issuance Issued To
92-04 RESOLUTION OF THE ISSUES 08/19/92 ALL BWR LICENSEES
RELATED TO REACTOR VESSEL FOF OPERATING
WATER LEVEL INSTRUMENTATION IN REACTORS
BWRs PURSUANT TO IOCFR50.54(F)
90-02 ALTERNATIVE REQUIREMENTS 07/31/92 ALL LWR LICENSEES
SUPPLEMENT 1 FOR FUEL ASSEMBLIES IN THE AND APPLICANTS
DESIGN FEATURES SECTION OF
TECHNICAL SPECIFICATIONS
87-02 SAFETY EVALUATION REPORT 05/22/92 ALL USI A-46 SUPPLEMENT 1 NO. 2 ON SQUG GENERIC LICENSEES WHO
IMPLEMENTATION PROCEDURE, ARE SQUG MEMBERS
REVISION 2.
92-03 COMPILATION OF THE CURRENT 03/19/92 ALL NUCLEAR POWER
LICENSING BASIS: REQUEST PLANT APPLICANTS
FOR VOLUNTARY PARTICIPATION AND LICENSEES
IN PILOT PROGRAM
92-01 REACTOR VESSEL STRUCTURAL 3/06/92 ALL HOLDERS OF OP
REVISION 1 INTEGRITY, 1OCFR5O.54(f) LICENSES OR CONST.
PERMITS FOR NUCLEAR
PWR PLANTS (EXCEPT
YANKEE ATOMIC FOR
92-02 RESOLUTION OF GENERIC 03/06/92 ALL HOLDERS OF OP
ISSUE 79, UNANALYZED REACTOR LICENSES OF CONST.
VESSEL (PWR) THERMAL STRESS PERMITS FOR PWRs DURING NATURAL CONVECTION
COOLDOWN
92-01 REACTOR VESSEL STRUCTURAL NOT ISSUED ALL HOLDERS OF OP
INTEGRITY, 1OCFR50.54(f) Revision LICENSES OR CONST.
Listed PERMITS FOR NUCLEAR
Above PWR PLANTS (EXCEPT
YANKEE ATOMIC FOR
- 89-10 CONSIDERATION OF VALVE 02/14/92 ALL LICENSEES OF OP
SUPPLEMENT 4 MISPOSITIONING IN BWRs NUC PWR PLANTS AND
HOLDERS OF CONSTRUCTION
- NOTE: 89-10 Supp. 4 -
Accession No. 9202070037 has been changed to 9202250311.
Systematic Assessment of Licensee Performance
,E " : :eK,.'c.z;i (SALP)
Directive (Formerly MC 0516) 8.6 DRAFT
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Systematic ssessment of Licensee Performance (SALP)
Directive 8.6 Contents Policy................................................................. I
Objectives ............................................................ 1
- Organizational Responsibilities and Delegations of Authority ........... 2 The Executive Director for Operations (EDO) ............................ 2 The Director, Office of Nuclear Reactor Regulation (NRR) ................. 2 Office Directors.................................................... 2 Regional Administrators. .............................................. 2 Applicability .................................................... 4 licensees ........................................................... 4 Employees .......................................................... 4 Handbook ............................................................. 4 Approved: (Draft 08/10/92) i T
U. S. Nuclear Regulatory Co. .mission
.° Volume: 8 Licensee Oversight Programs NRR
Systematic Assessment of Licensee Performance (SALP)
Directive 8.6 Policy
(8.6-01)
This directive and handbook govern the scope, objectives, authorities, responsibilities, and basic requirements of the Systematic Assessment of licensee Performance (SALP) Program. The SALP is an integrated agency effort to collect and evaluate available agency insights, data, and other information on a plant/site basis in a structured manner in order to assess and better understand the reasons for a licensee's per- formance. The manner in which a licensee meets regulatory requirements and the degree to which a licensee seeks to improve performance are both measures of a licensee's commitment to nuclear safety and plant reliability.
Objectives
(8.6-02)
- To conduct an integrated assessment of licensee performance from the findings and conclusions of the NRC during an assessment period in a manner that highlights strengths and weaknesses. (021)
- To provide a vehicle for meaningful dialogue with the licensee regarding its performance based on the insights gained from long-term synthesis of NRC observations. (022)
- To assist NRC management in making sound decisions regarding allocation of NRC resources used to oversee, inspect, and assess licensee performance. (023)
Approved: (Draft 08/10192) I
Systematic Assessmerjf Licensee __
Performance (SALP)
Directive 8.6 Organizational Responsibilities and Delegations of Authority
(8.6-03)
The Executive Director for Operations (EDO)
(031)
Provides oversight for the activities described in this directive and handbook.
The Director, Office of Nuclear Reactor Regulation (NRR)
(032)
- Implements the requirements of this directive within NRR. (a)
- Monitors the SALP process. (b)
- Evaluates and develops SALP policy, criteria, and methodology. (c)
- Assesses the uniformity and adequacy of the implementation of the program. (d)
Office Directors
(033)
- Implement the requirements of this directive within their respective offices. (a)
- Confer with the Director, NRR, and inform the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations, and Research (DEDR) when contemplating significant deviations from the requirements or guidelines of this directive. (b)
Regional Administrators
(034)
- Implement the requirements of this directive within their respective regions. (a)
2 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Directive 8.6 Regional Administrators
(034) (continued)
- Confer with the Director, NRR, and inform the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations, and Research (DEDR) when contemplating significant deviations from the requirements or guidelines of this directive. (b)
- With input from the SALP Board-(c)
- Issue the initial SALP report. (i)
- Evaluate the licensee's comments on the report and the adequacy of the licensee's commitments to improve performance. (ii)
- Issue the final SALP report. (iii)
- Direct reallocation of regional inspection resources, as and when appropriate. The regional administrator should consider reducing the level of inspection effort for SALP Category 1 functional areas, consider maintaining the level of inspection effort for Category 2 functional areas, and consider increasing the level of inspection effort for SALP Category 3 functional areas. (d)
- Authorize changes and the basis for the changes to initial SALP
reports, as appropriate. (e)
- Establish a schedule, establish NRC participation, and determine a site for a meeting with the licensee to ensure mutual understanding of the issues discussed in the SALP report. (f)
- Suspend the SALP process for any plant that is placed on the Category 3 list of problem facilities as a result of the Senior Management Meeting process. The SALP process should not resume until the facility is removed from this category. (g)
- Assess the uniformity and adequacy of regional implementation of the SALP Program. Provide to the Director, NRR,
recommendations for improving the SALP Program. (h)
Systematic Assessmeh-f Licensee Performance (SALP)
Directive 8.6 Applicability
(8.6-04)
Licensees
(041) a This program applies to all licensees of power reactors with operating licenses or construction permits.
Employees
(042)
The provisions of this directive and handbook apply to and must followed by NRC headquarters and regional personnel. be Handbook
(8.6-05)
Major components of the SALP Program are specified Handbook in
8.6.
4 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance SS.'.'S. . :;'.,>,..: ..:SX.:>:.:.:.:.i
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(SALP)
Handbook (Formerly f j Appendix 0516) 8. 6
Systematit ssessment of Licensee Performance (SALP)
Handbook 8.6 Parts I - III
Contents Introduction ......... 1 Part I
Implementing Instructions for the SALP Program ................... 3 Evaluation Frequency (A) ........................................... 3 Evaluation Process (B)............................................. 4 Functional Areas (C) .............................................. 5 Operating Phase Reactors (D)........................................ 6 Plant Operations (1) ............................................ 6 Maintenance (2) ................................................ 6 Engineering (3) ................................................ 7 Plant Support (4) ............................................... 7 Other Functional Areas (as appropriate) (5) ........................ 7 Construction Phase Reactors (E) ............................. .......... 7 Soils and Foundations (1) .......................... ' .......... 7 Containment, Major Structures, and Major Steel Supports (2) ......... . 8 Piping Systems and Supports (3) ......................... .......... 8 Mechanical Components (4) ............................. .......... 8 Auxiliary Systems (5) .................................. .......... 9 Electrical Equipment and Cables (6) ...................... .......... 9 Instrumentation (7) .................................... .......... 9 Engineering and Design Change Control (8) ............... .......... 9 Other Functional Areas (as appropriate) (9) ............... .......... 10
Evaluation Criteria (F) .............................- .......... 10
Performance Ratings (G) ................................... .......... 10
Performance Trend (H) ............................. ; .......... 12 Part II
Evaluation Criteria.................................................. 13 Approved: (Draft 08/10/92) i
Performance (SALP)
Handbook 8.6 Parts I - III
Contents (continued)
Part III
Implementation of the SA.LP ....................
14 Assessment by the SALP Board (A) . . .14 Preparation for the SALP Board Meeting (1) .. 14 SALP Board Meeting (2) . . .15 Issuance of the Initial Report (B) . . .17 Meeting With the licensee (C) . . .18 General (1) . . .18 Meeting Preparation (2) .. 19 Licensee Meeting (3) . . .19 Format and Content of the SAyP Report D) . . .20
General (1) . . .20
Report Format and Content (2) . . .21 Final SALP Report (E) . . .21 General (1) . . .21 Specifics of the Final SALTP Report (2) . . .21 Changing the Initial SALP Report (3) .. 22 Exhibits
1. SALP Evaluation Process .23
2. Evaluation Criteria and Attributes for Assessment of Licensee Performance . .
24
3. Evaluation Matrix for Operating Phase Functional Areas .32
4. Evaluation Matrix for Construction Phase Functional Areas .33
5. SALP Report [Initial or Final] .34
6. Sample SALP Board Report Revision Sheet ..........................
38
7. Sample Revised Page .39
8. Sample Original Page .40
- ,Approved
- (Draft 08/10/92)
I
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Introduction Introduction The SALP process is used by the NRC to synthesize its observations of and insights into a licensee's performance and to identify common themes or symptoms. Thus, the NRC needs to recognize and understand the reasons for a licensee's strengths as well as weaknesses.
Unacceptable performance is addressed through various NRC
programs and policies, and the implementation of these activities should not be delayed to await the results of a SALP assessment. (A)
The primary product of the SALP process is the SALP report, which is addressed in Part III of this handbook. The results of the SALP process as documented in the SALP report are used to express NRC senior management's observations and judgments on the licensee's performance. The SALP should not be limited to weaknesses and is not intended to propose problem resolutions or solutions. The licensee's management is responsible for ensuring plant safety and establishing effective means to measure, monitor, and evaluate the quality of all aspects of plant design, hardware, and operation. (B)
The SALP process is intended to further NRC's understanding of (1)
how the licensee's management guides, directs, evaluates, and provides resources for safe plant operations and (2) how effective these actions are. Performance indicators should not be a factor in judging the effectiveness of or rating a particular functional area.
Although indicators may correspond in varying degrees to SALP
functional areas, the Performance Indicator Program is separate and distinct from -the SALP Program. Indicators such as failure of a plant's safety systems or frequent forced outages because of equipment failures may be symptomatic of safety problems. Thus, events and failures captured by the program may appear in SALP discussions and reports. However, these SALP references are to be based on the underlying causes of poor performance and not on the results of the Performance Indicator Program (see NRC Announcement 200,
"Revised Guidance on the Use of Performance Indicators,"
November 28, 1989). (C)
Approved: (Draft 08/10/92) 1
-oiatcluazm. ts: >UtvacL w licensee Performance (SALP)
Handbook 8.6 Intro, -tion Introduction (continued)
As a result, the SALP process emphasizes understanding the reasons for a licensee's performance in identified functional areas and on sharing this understanding with the licensee and the public. The SALP
process is intended to provide meaningful feedback to a licensee's management and to be sufficiently diagnostic to provide a rationale for allocating NRC resources. (D)
2 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part I
Part I
Implementing Instructions for the SALP Program Evaluation Frequency (A)
The NRC will normally review and evaluate each power reactor licensee that possesses an operating license or a construction permit at least every 18 months, except in the following instances: (1)
- When a new operating license is issued, two consecutive SALP
evaluations should be scheduled at approximately 12-month intervals. The first of these two evaluations should be scheduled for completion approximately 12 months after the low-power license is issued. The second of these two evaluations should be completed approximately 12 months later. Following completion of these two evaluations, a determination should then be made on whether to place the licensee on a normal SALP schedule. (a)
- When the regional administrator determines that the performance of a particular utility or facility warrants a more frequent evaluation, the normal SALP frequency may be increased. For example, in the case of a licensee that was assigned a Category 3 performance rating in one or more functional areas during the previous evaluation, the period between SALP evaluations may be reduced to about 12 months. The regional administrator may elect to conduct additional management meetings with the licensee to monitor the licensee's self-assessment efforts and performance progress following a SALP with poor ratings, rather than or in addition to reducing the length of the assessment period. (b)
- The region may reduce the SALP cycle length to less than
18 months in order to avoid schedular conflicts. (c)
Approved: (Draft 08/10/92) I 3
reriormance (SALP)
Handbook 8.6 Part I
Evaluation Frequency (A) (continued)
- The assessment period may be extended to a maximum of
24 months, with the concurrence of the Director, NRR, when a plant meets the screening criteria established for superior performance recognition by the NRC Senior Management Meeting for two consecutive SALP evaluation cycles. (d)
- When circumstances warrant, the normal SALP frequency may be suspended. Infrequent SALPs may be indicated for plants in extended shutdowns, extended outages, or decommissioning, and some aspects of the SALP evaluation may not be applicable. Plants in these circumstances are typically covered by separate assessment and readiness review programs. In these cases, the regional administrator shall confer with the Director, Office of Nuclear Reactor Regulation (NRR), and document the basis for suspending the normal SALP frequency. (e)
- In particular, the SALP process should be suspended for any plant that is shut down and requires Commission (not staff)
authorization to restart. As a part of a restart review process, an ungraded evaluation of performance and trends in the SALP
functional areas may be performed. (f)
For licensees that operate plants at more than one site, or that operate plants at one site that may be in different stages, such as the construction stage, the preoperational stage, or power ascension from an extended outage, an individual assessment will usually be performed. (2)
For licensees that operate plants at one site that are of significantly different design, the regional administrator will determine if individual assessments are necessary to capture and communicate the NRC's assessment of licensee performance for these plants. For licensees that operate plants at a multiple-unit site, one assessment for a common functional area may be appropriate. (3)
For licensees of multiple facilities such as Duke Power Co., Tennessee Valley Authority, and Commonwealth Edison, each site must have separate SALP report. (4) a Evaluation Process (B)
The evaluation process, illustrated in Exhibit 1 of this handbook, is summarized as follows: (1)
4 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part I
Evaluation Process (B)(continued)
- Conduct a SALP using the evaluation criteria contained in Part II
of this handbook. (a)
- Issue the SALP report. (b)
- Conduct a public meeting with the licensee's management to discuss the assessment. Normally the meeting will be conducted on site or in the vicinity of the site when feasible to foster more widespread understanding of the NRC's views. (c)
- Consider any written response received from the licensee. A final SALP report will be issued and will include the written response received from the licensee and any changes to the SALP report based on the regional administrator's review of the licensee's response. (d)
General guidance regarding the implementation of the SALP is provided in Part III of this handbook. Specific guidance for the implementation and conduct of the SALP process is contained in the operating procedures of each responsible office and region. (2)
Functional Areas (c)
Functional areas represent a grouping of similar licensee activities.
Each functional area evaluated will be assigned a category rating. The evaluation criteria and associated attributes against which the functional areas are to be evaluated are provided in Part II of this handbook. Note that it is inappropriate to refer to Performance Indicator Program results in forming a SALP rating. (1)
The category ratings assigned to individual functional areas are only one aspect of the SALP process. The SALP Board is expected to assess each functional area in such a manner that the discussion focuses on understanding the reasons for the observed performance. The attributes and assessment criteria provided in Part II of this handbook should be relied on to develop a uniform and consistent approach.
After assessing all the functional areas, the SALP Board is expected to discuss any commonalities among the functional areas. This process of reviewing the summary results from the standpoint of identifying common underlying reasons for the licensee's performance is the basis of the "Overview" section of the report. The overview should also note Approved: (Draft 08/10/92)
_- x:1 yurmlanct 3A1,r)
Handbook 8.6 Part I
Functional Areas (C) (continued)
functional areas in which ratings have changed since the period and discuss the reasons for these changes. (2) previous To emphasize topics for consideration beyond the specified functional areas, NRR may include selected topics as part of the overview.
topics will be addressed by all SALP Boards for aldefined period,These the summary results will be presented as part of the overview. and
(3)
Operating Phase Reactors (D)
The functional areas for operating reactors are- Plant Operations (1)
This functional area consists chiefly of the control and execution activities directly related to operating a plant. It includes activities of as plant startup, power operation, plant shutdown, and system such Thus, it includes activities such as monitoring and logginglineups.
conditions, normal operations, response to transient and off-normal plant conditions, manipulating the reactor and auxiliary controls, room professionalism, and interface with activities that control operations. It also includes initial and requalification training support licensed operators. of Maintenance (2)
This functional area includes all activities associated with diagnostic, predictive, preventive, or corrective maintenance either structures, systems, and components, or maintenance of the of plant condition of the plant. It also includes conduct of all surveillance physical (diagnostic) testing activities, as well as all inservice inspection testing activities. Testing activities also include instrument and calibrations; equipment operability tests; post-maintenance, post-modification, and post-outage testing; containment tests; special tests; inservice inspection and performance leak rate pumps and valves; and all other inservice inspection activities.tests of
6 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part I
Operating Phase Reactors (D) (continued)
Engineering (3)
This functional area addresses the adequacy of technical and engineering support for'all plant activities. It includes all licensee activities associated with design control; the design and installation of plant modifications; engineering and technical support for operations, outages, maintenance, testing, surveillance, and procurement activities; configuration management; design basis reconstitution; and support for licensing activities related to amendment, exemption, and relief request.
Plant Support (4)
This functional area covers all activities related to plant support functions, including radiological controls, emergency preparedness, security, housekeeping controls, chemistry, and fire protection. It includes all activities associated with occupational radiation safety, radioactive waste management, radiological effluent control and monitoring, transportation of radioactive materials, licensee performance during emergency preparedness exercises and actual events that test emergency plans, emergency plan notifications, interactions with onsite and offsite emergency response organizations during exercises and actual events, and safeguards measures that protect plant equipment, including physical security, fitness-for-duty, access authorization, and control of special nuclear material.
Other Functional Areas (as appropriate) (5)
When plants are in extended shutdowns, it may be more appropriate to address shutdown operations in lieu of plant operations. For readiness assessments, SALP Boards may need to consider activities that take place over a shorter interval, such as startup testing.
Construction Phase Reactors (E)
The functional areas for construction phase reactors are- Soils and Foundations (1)
This functional area includes all activities pertaining to soils and foundations related to the construction of the ultimate heat sink and Approved: (Draft 08/10/92) 7
Systematic Assessment of Licensee Performance (SALP, .
Handbook 8.6 Part I
Construction Phase Reactors (E) (continued)
Soils and Foundations (1) (continued)
major structures. Specifically, this area covers, as applicable, subgrade investigation and preparation, fill materials and compaction, embankments, foundations and associated laboratory testing, and related instrumentation and monitoring systems.
Containment, Major Structures, and Major Steel Supports (2)
This functional area includes all activities related to the structural concrete and steel used in the containment (including the basemat),
major structures, and major steel equipment supports. It covers all aspects of structural concrete (e.g., reinforcing steel; concrete batching, delivery, placement, in-process testing, and curing; liner plate erection and fabrication; and containment post-tensioning),
structural steel used in safety-related structures (welded and bolted),
and major steel equipment supports (for the reactor vessel, reactor coolant pumps, steam generators, the pressurizer, the polar crane, tanks, heat exchangers, etc.).
Piping Systems and Supports (3)
This functional area includes those piping systems described in the licensee's safety analysis report (SAR) that affect the safe operation of the plant. It includes those activities and quality checks such as fabrication, installation, configuration, welding, nondestructive examination, and preservice inspection necessary to ensure compliance with the applicable codes and other requirements specified in the safety analysis report, specifications, and implementing procedures.
Mechanical Components (4)
This functional area covers mechanical components such as pressure vessels; reactor vessel internals, pumps, and valves located in, and attached to, the piping systems described under the preceding functional area. The primary emphasis is on discrete components rather than piping or systems.
8 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part I
Construction Phase Reactors (E) (continued)
Auxiliary Systems (5)
This functional area includes those auxiliary systems in the nuclear facility that are essential for the safe shutdown of the plant or the protection of the health and safety of the public. It includes systems such as the heating, ventilation, and air conditioning; radwaste; fire protection; and fuel storage and handling systems.
Electrical Equipment and Cables (6)
This functional area includes important electrical components, cables, and associated items used in the electrical systems of the plant, such as motors; transformers, batteries, emergency diesel generators, motor control centers, switchgear, electric raceways, cable (power, control, and instrument), circuit breakers, relays, and other interrupting and protective devices.
Instrumentation (7)
This functional area covers 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 examples of covered plant systems. Also included are devices such as sensors, transmitters, signal conditioners, controllers, and other actuating devices, recorders, alarms, logic devices, instrument air supplies.
racks, and panels.
Engineering and Design Change Control (8)
This functional area addresses the adequacy of the technical and engineering support for all plant activities. It includes all licensee activities associated with the design of the plant; engineering and technical support for maintenance, testing, surveillance, procurement, and preoperational, startup, and operational activities; training; and configuration management, including maintaining design bases and safety margins; and licensee activities related to exemption and relief requests.
Approved: (Draft 08/10/92) 9
Systematic Assessment of Licensee Performance (SALP'-
Handbook 8.6 Part--
Construction Phase Reactors (E) (continued)
Other Functional Areas (as appropriate) (9)
For reactors in the preoperational phase, functional areas listed for either operating phase reactors or construction phase reactors should be selected, as appropriate. For reactors in the startup phase, functional areas listed for operating phase reactors should be used.
Evaluation Criteria e licensees will be evaluated in the functional areas described above, using the following evaluation criteria. Part II of this handbook describes a number of attributes for each evaluation criterion and provides guidance on using these criteria to assign a performance rating. The evaluation criteria are as follows:
- Management involvement and control in assuring safety (1)
- licensee's self-assessment capability (2)
- Approach to the resolution of safety issues and effectiveness of corrective action (3)
- Operational and construction events (4)
- Staffing and application of resources (5)
- Effectiveness of training and qualification (6)
- Enforcement history (7)
Performance Ratings (G)
The SALP Program is a mechanism for assessing the quality of licensee activities and safety performance in selected functional areas.
Licensees assigned a Category 1 rating in a functional area have clearly demonstrated superior performance, which may justify some relaxation in NRC oversight. Conversely, licensees assigned a Category 3 rating in a functional area are of concern to NRC, and NRC
will consider additional interaction with and oversight of the licensee. (1)
10 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part I
Performance Ratings (G) (continued)
The functional area being evaluated may have some attributes that merit a Category I rating and others that merit either a Category 2 or a Category 3 rating. The final rating for each functional area will be a composite rating of the attributes based on a knowledgeable balancing of experiences and safety significance by senior NRC managers and staff. Statistical or numerical balancing is inappropriate. (2)
The following performance categories are used to rate licensee performance: (3)
- Category 1. Licensee management attention to and involvement in nuclear safety or safeguards activities resulted in a superior level of performance. (a)
- Category 2. Licensee management attention to and involvement in nuclear safety or safeguards activities resulted in a good level of performance. (b)
- Category 3. licensee management attention to and involvement in nuclear safety or safeguards activities resulted in an acceptable level of performance. However, because the margin to unacceptable performance in important aspects is small, NRC and licensee attention is required. (c)
- Category N. Insufficient information exists to support an assessment of licensee performance. These cases include instances in which a rating cannot be developed because of insufficient licensee activity or insufficient NRC inspection. This category is normally used for construction phase reactors only. (d)
The SALP is not intended as a substitute for NRC enforcement action.
Enforcement action should not await the outcome of a SALP but should be taken at the time the unacceptable action or event occurs. In this regard, the SALP process can assist NRC management by providing perspective; but it is not a substitute for effective enforcement action. When licensees cannot consistently meet regulatory requirements, the affected plants will be considered for escalated enforcement action, including enforcement resulting in shutdown. (4)
Approved: (Draft 08/10/92) 11
rerlormance tBALr)
Handbook 8.6 Part I
Performance Trend (H)
NRC should examine licensee performance during the assessment period to determine whether a trend exists. Of particular interest are those licensees with a Category 3 performance rating and a declining trend. If senior NRC management has not been previously informed, these situations should be brought to the attention of the Director, NRR; the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations,' and Research; and the regional administrator. (1)
The performance trend should be determined selectively and should be reserved for those instances in which it is necessary to focus the attention of NRC and the licensee on an area with a declining performance trend, or to acknowledge an improving trend in licensee performance. (2)
The trend, if used, may be defined as either improving or declining: (3)
- Improving. licensee performance was determined to be improving
- during the assessment period and continuation of the trend may result in a future change in category rating. (a)
- Declining. licensee performance was determined to be declining during the assessment period and continuation of the trend may result in a future change in category rating. (b)
12 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part II
Part II
Evaluation Criteria NRC assesses licensee performance by applying seven evaluation criteria to each functional area. Exhibit 2, "Evaluation Criteria and Attributes for Assessment of Licensee Performance," lists the attributes associated with each criterion. (A)
The seven criteria and their associated attributeswill aid the NRC staff in understanding and evaluating licensee performance by identifying the causes and factors associated with Categories 1, 2, and 3. It is not intended that consideration of these attributes influence established agency programs. For example, it is not intended that the staff perform specific inspections to evaluate attributes. It is expected that during the implementation of established programs, the staff will observe many of the attributes that describe performance. Awareness and consideration of these attributes should assist the staff in its observation of licensee performance during routine activities. (B)
All attributes of the evaluation criteria are not necessarily applicable to each licensee during each SALP period. For example, performance within a functional area may be insufficient to consider all attributes in the assessment. However, the criteria should be considered in the evaluation of each functional area to the extent appropriate. (C)
All available information should be analyzed by the SALP Board and the regional administrator. The significance of the information, whether 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. (D)
Exhibit 3, "Evaluation Matrix for Operating Phase Functional Areas,"
and Exhibit 4, "Evaluation Matrix for Construction Phase Functional Areas," provide a format that may be useful to the SALP Board in assessing and recording licensee performance. (E)
Approved: (Draft 08/10/92) 13
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part IL-,
Part III
Implementation of the SALP
Assessment by the SALP Board (A)
Preparation for the SALP Board Meeting (1)
To prepare for the SALP Board meeting, each region shall-
- Issue a memorandum establishing the assessment period, the due date for SALP Board input, and scheduled dates for the SALP
Board meeting, the licensee management meeting, and issuance of initial and final SALP reports for all facilities within the region scheduled for a SALP during the fiscal year. The regions shall distribute this memorandum to the Office of Nuclear Reactor Regulation (NRR), including the NRR SALP coordinator, the Office of Nuclear Material Safety and Safeguards (NMSS), the Office for Analysis and Evaluation of Operational Data (AEOD),
the Office of Nuclear Regulatory Research (RES), and the Executive Director for Operations (EDO) by the end of the preceding fiscal year. The regions shall provide any changes to SALP schedules to these offices. The applicable SALP data in SINET should be updated as appropriate. SALP Board members should be notified promptly of any scheduling problems to facilitate coordination of alternative meeting dates. (a)
- Prepare a working copy of the SALP report. (b)
- Integrate SALP report inputs. NRR shall provide written input for each functional area, as appropriate. (i)
- Prepare the "Supporting Data Summary" section of the report.
See Exhibit 5, "[Initial or Final] SALP Report," for format. (ii)
- Prepare a performance analysis for each functional area. (iii)
14 4Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part III
Assessment by the SALP Board (A) (continued)
Preparation for the SALP Board Meeting (1) (continued)
- Issue the working copy of the SALP report to SAL! Board participants before the SALP Board meeting. Note that this version of the report should not contain recommended licensee performance ratings. (iv)
SA1 !PBoard Meeting (2)
The SALP Board meeting will be conducted in accordance with the regional SALP implementation procedures. (a)
The composition of the SALP Board is multidisciplinary in nature and is intended to result in an integrated assessment of licensee performance. Specification of the board's voting members is not meant in any way to limit presentations before the board by other NRC
staff members when such presentations are appropriate. Rather, the staff members closely associated with a functional area should be asked to discuss their views with the SALP Board. (b)
Proper preparation for the SALP Board meeting is essential for voting members since they are expected to participate in board discussions of each functional area in order to contribute effectively to the assessment of the licensee's performance and the identification of common themes and symptoms of that performance. All board voting members should (1) have visited the site during the assessment period and reviewed plant performance and (2) be familiar with inspection report findings that were issued during the assessment period. The regional administrator may exempt specific board members on a case-by-case basis from these requirements. To effectively support the goals of the "Overview" section of the report, it is important that the board voting membership remain constant during the evaluation process. As a result, SAL!P Board deliberations should be oriented toward reaching a consensus view, when possible. (c)
The SALP Board will be composed of the following members, with each member having a vote: (d)
One representative from each of the region's projects and technical divisions. Each divisional representative will be a division director, a deputy division director, a branch chief, or a section chief. (i)
Approved: (Draft 08/10/92) 15
Handbook 8.6 Part III
Assessment by the SALP Board (A)(continued)
SALP Board Meeting (2) (continued)
- The senior resident inspector. (ii)
- The NRR project manager. (iii)
- An NRR SES-level manager. (iv)
Others: The regional administrator may designate an additional or substitute voting member, normally an SES-level manager, for any specific board. For example, an out-of-region SES-level manager or a startup reviewteam leader who has conducted an indepth review of the facility may be appropriate. Use of board-specific voting members is expected to be infrequent. Because of the combination of reactor projects and reactor safety in Region V, the Regional Administrator for Region V may appoint two representatives from the Division of Reactor Projects and Safety to ensure both the reactor projects and reactor safety perspectives are represented on each board. (e)
The SALP Board Chairperson will be a regional SES-level manager and will be the divisional representative, but will not serve in addition to the divisional representative. When multiple NRR project managers are assigned to different units at the same site, the project managers shall cast one collective vote. A board quorum will consist of a minimum of five persons. Generally, there should be no more than seven voting members on the board. (f)
During the SAL? Board meeting-(g)
report. They shall ensure that each functional area section concisely conveys the board's views, with selected examples to illustrate key findings. They shall ensure that a conclusion has been reached regarding licensee performance within each functional area. They shall ensure that the discussion of performance within each functional area identifies common themes or symptoms of that performance, if known. (i)
16 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part III
Assessment by the SALP Board (A) (continued)
SALP Board Meeting (2) (continued)
- The SALP Board members shall evaluate licensee performance in each functional area after considering the evaluation criteria with their associated attributes listed in Exhibit 2. Exhibits 3 and 4 may be used by the SALP Board members to assist them in assigning a category rating for each functional area. The functional area category ratings will be determined by a majority vote of the board's voting members. (ii)
- The SALP Board members should recommend changes to the NRC inspection program for implementation.. at the specific facility, as appropriate. (iii)
- The SALP Board members shall identify weaknesses and/or recommend areas for the licensee's consideration so that improvement in performance can be addressed. (iv)
- The SALP Board Chairperson shall ensure that the licensee's overall performance is discussed and assessed, with an emphasis on identified strengths and weaknesses. (v)
Following the SALP Board meeting, the SALP Board Chairperson shall provide a SALP Board report with its recommended ratings and overview to the regional administrator. The regional administrator may make substantive changes to the report before it is issued to the licensee. If changes are made, the regional administrator should so inform the SALP Board Chairperson. (h)
Issuance of the Initial Report (B)
The regional administrator shall sign and issue the initial SALP report (Exhibit 5) to the licensee at least 2 weeks before the meeting with the licensee. Copies of the report should also be provided to the offices of the EDO; the Director, NRR; the Director, Office of Enforcement; the Commissioners; and the NRR Division of licensee Performance and Quality Evaluation (DLPQ) SALP Program Manager. The letter transmitting the SALP report will be distributed on a timely basis as a standard docket item to the Document Control System, the NRC
Public Document Room, the appropriate Local Public Document Room, and the Institute of Nuclear Power Operations (Record Approved: (Draft 08/10/92) 17
- cB &%JA .bL
korLai J
Handbook 8.6 Part IlI
Issuance of the Initial Report (B)(continued)
Center, Institute of Nuclear Power Operations, 1100
75 Parkway, Suite 1500, Atlanta, GA 30339). Each report Circle assigned an inspection report number. (1) will be The transmittal letter for the initial SALP report should include following: (2) the C
- A characterization of overall safety performance consistent the "Overview" section of the SALP report. The SALP transmittal with letter must highlight common themes of licensee performance identified by the SALP process. The transmittal letter should strive to characterize NRC's confidence in or concern with the licensee's performance and the underlying reasons therefor and should place in perspective any significant events or findings that took place outside the assessment period that bear on the evaluations in report. Specifically, the regional administrator shall highlight the the SALP cover letter those areas of performance that have in declined since the end of the assessment period. The regional administrator should ensure the transmittal letter is consistent the results of any other current events and processes related towith plant's performance, such as results of recent Senior Management the Meetings and major team inspections, to ensure that conflicting messages are not inadvertently transmitted to the licensee. (a)
- Areas or issues that warrant discussion during neeting the licensee. (b) with the
- A request for the licensee's written comments on and amplification of, as appropriate, the SALP report within 30 days meeting with the licensee. For all functional areas after rated as the Category 3, the transmittal letter must require a response from the licensee that provides planned corrective actions to improve performance. (c)
Meeting With the Licensee (c)
General (1)
A public meeting with the licensee's management to discuss assessment will be held following issuance of the initial SALP the The meeting will be conducted on site or in the vicinity of the report.
site, if
18 Approved: (Draft 08/10/92)
Systematic -' ssessment of Licensee Performance (SALP)
Handbook 8.6 Part III
Meeting With the Licensee (C)(continued)
General (, (continued)
feasible, to foster accessibility and a more widespread understanding of the NRC's views.
Meeting Preparation (2)
The region shall notify those on distribution for the SALP report of the meeting with the licensee. (See Section (B) of Part III of this handbook.) (a)
The region shall notify the media and State and local government officials of the issuance of the initial SALP report and of the meeting with the licensee once the report has been released. Generally, at least I week's notice should be provided before the meeting. (b)
The licensee should be encouraged to have the following management representatives participate in the meeting: (c)
- The senior corporate nuclear officer/manager (i)
- Management officials responsible for the major functional areas (ii)
- The site manager (iii)
Licensee Meeting (3)
The meeting should be conducted within 90 days of the end of the assessment period. (a)
The regional administrator will determine the NRC participants for the licensee meeting. NRC participants for this meeting typically include the following: (b)
- The regional administrator or the deputy administrator, especially if licensee performance has been rated as Category 3, or Category 2 with a declining trend. (i)
- The SALP Board Chairperson or other SES voting member of the board. (ii)
Approved: (Draft 08/10/92) 19
Systematic Assessmer* of Licensee Performance (SALP) --'
Handbook 8.6 Part III
Meeting With the Licensee (C) (continued)
Licensee Meeting (3) (continued)
- Responsible regional division directors, branch chiefs, or section chiefs, as appropriate. (iii)
- The resident inspector and/or assigned inspectors. (v)
- A public affairs officer, when media interest is anticipated. (vi)
The regional administrator, the deputy administrator, or the SALP
Board Chairperson will chair the meeting. These meetings are intended to provide a forum for a candid discussion of issues relating to the licensee's performance. Those aspects of the licensee's operation that need improvement will be identified, as well as the positive aspects of the licensee's performance. The licensee also will be given the opportunity to provide comments on the report in writing within
30 days after the meeting. Only written comments from the licensee must be subsequently addressed by the regional administrator. (c)
SALP management meetings with the licensee should be public meetings, unless portions of the meetings involve discussion of matters that are required to be withheld from the public domain pursuant to Section 2.790 of Title 10 of the Code of. Federal Regulations
(10 CFR 2.790). For those portions, the meeting must be closed.
Members of the public, the press, and Government officials should be treated as observers. Adequate notification of the SALP meeting should be accomplished by the timely distribution to the Public Document Room of the letter scheduling the meeting with the licensee, with copies to the parties on the service list for the appropriate docket. (d)
Format and Content of the SALP Report (D)
General (1)
The SALP report is considered a final report once the regional administrator has signed the transmittal letter to the licensee following the meeting with the licensee and after consideration of the licensee's written response, if any.
20 Approved: (Draft 08/10/92)
Systematic msessment of Licensee Performance (SALP)
Handbook 8.6 Part III
Format and Content of the SALP Report (D)(continued)
Report Format and Content (2)
The staff shall prepare the SALP report in general conformance with the guidelines of Exhibit 5 of this handbook.
Final SALP Report (E)
General (1)
The regional administrator shall issue the final SALP report within 30
days of receipt of the licensee's written comments or planned corrective actions. This report will receive the same distribution as the initial SALP report.
Specifics of the Final SALP Report (2)
The final SALP report must normally consist of the following: (a)
- The initial SALP report, with any changes made after the meeting with the licensee. (i)
- A summary of the meeting held with the licensee concerning the initial SALP report. (ii)
- A copy of the written comments received from the licensee. (iii)
- NRC's conclusion regarding the acceptability of the licensee's planned corrective actions, if corrective actions are required. (iv)
- The conclusions of the regional administrator based on consideration of the licensee's comments and planned corrective actions. (v)
If the licensee's response does not result in any change to the initial report, or if the licensee chooses not to respond, the final SALP report transmittal may consist of the following: (b)
- A summary of the meeting held with the licensee concerning the initial SALP report. (i)
- A copy of the licensee's written response, if any. (ii)
Approved: (Draft 08/10/92) 21
Systemafic Assessment of Licensee Performance (SALP)
Handbook 8.6 Part Lo.
Final SALP Report (E) (continued)
Specifics of the Final SALP Report (2) (continued)
- The transmittal letter that clearly references the date of issuance of the initial SALP report and a statement that the initial report is considered to be the final SALP report. (iii)
Changing the Initial SALP Report (3)
Any changes to the initial SALP report after the meeting with the licensee will require the following actions:
- Generate a cover letter signed by the regional administrator that authorizes the change, the basis for the change, and its impact on the SALP results. (a)
- Attach a "SALP Board Report Revision Sheet" (Exhibit 6) as a separate enclosure to the regional administrator's cover letter denoting the change and the basis for the change. (b)
- Add the revised page (Exhibit 7, "Sample Revised Page") to the report, leaving the original page (Exhibit 8, "Sample Original Page") in the report. Use a sidebar to indicate area of change.
Renumber the page (original page 5 would become page 5A). (c)
- Draw a diagonal line through the original page as shown on Exhibit 8 and reference the revision sheet. (d)
- Reissue the final SALP report in its entirety with corrections noted above. (e)
22 Approved: (Draft 08/10/92)
Systematic -'ssessment of Licensee
- Performance (SALP)
Handbook 8.6 Exhibits Exhibit 1 SALP Evaluation Process SALP EVALUATION PROCESS SCHEDULAR GOALS
End of Assessment Period I
SALP Board Preparation SALP Board Meeting I Initial SALP
Report Issuance I
Y .
I Meeting With the Licensee Within
90 days Licensee Within Response 30 days Final SALP Within Report Issuance 30 days Approved: (Draft 08/10/92) 23
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I Category 1
1. Management Involvement and Control in Assuring Safety Category 2 Category 3 or M
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a. Prior planning results in a. Prior planning results in a. Prior planning, although ac- ox safe plant operations and safe plant operations and ceptable, is not.effective as ;:h excellent coordination of good coordination of plant evidenced by, for example, N."
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ments is excellent. effective, with some minor safe plant operations are not I_
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b. Policies and procedures b. Policies and procedures b. Policies and procedures are X
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b. Self-assessments involve all b. Self-assessments normally licensee organizations and involve all licensee organi- b. Self-assessments are iso- result in effective identifi- zations and usually result in lated and narrowly focused.
cation of potential prob- identification of potential lems. problems. 5 c. Line organization involve- c. Line organization involve- c. Line organization involve- f_-
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ment, safety review corm- ment, safety review commit- ment, safety review commit- k4 mittees (independent safety tees, and feedback from tees, and feedback from engineering group [ISEG], QA/QC activities are nor- QA/QC activities are slow onsite and offsite review mally used to provide self- to identify deficient condi- _i.
committees, etc.), and assessments and improve tions, as evidenced by prob- :3 feedback from quality work activities, although lem areas that are AD0
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effectively used to provide case. assessments.
critical self-assessment and improve work activities.
d. Industry and in-house expe- d. Industry and in-house expe- d. Industry and in-house expe- rience is effectively utilized rience is normally utilized rience is not effectively util- to identify and resolve to identify and resolve po- ized, as evidenced by a sig- M-_
potential problems. tential problems, although nificant issue or numerous.
some examples exists in minor issues developing to which minor issues were from previously identified misclassified and therefore industry problems.
it% unresolved.
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a. Evaluations of technical a. Evaluations of technical a. A clear understanding of the
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technical issues displayed a Ar- weak understanding of the safety implications.
b. Conservatism is routinely b. Conservatism is usually b. Minimum requirements are exhibited when the poten- exhibited. met.
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Category 1 Category 2 Category 3 e. Resolutions are timely in e. Resolutions are generally e. Resolutions are sometimes almost all cases. timely. delayed on significant issues or frequently delayed on minor issues.
f. Excellent corrective action f. Good corrective action is f. Corrective actions are ac- is apparent through elimi- apparent through reduction ceptable; however, causal nation of causal factors for of most causal factors of factors reappear in plant is- plant issues. plant issues. sues that indicate actions 5 have not been thorough.
g. Root cause analyses are g. Root cause analyses are g. Root cause analyses often X
thoroughforsignificantand good for significant issues. do not probe far enough, as minor issues and address all Some minor issues that may resulting in incomplete -
relevant contributors to the not receive as thorough a identification of root causes issues. root cause analysis result in and recurrence of plant recurrence of minor issues. issues.
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causes under the licensee's control. control.
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b. Events are properly identi- b. Events are identified, ana- b. Events are poorly identi- fied, analyzed, and re- lyzed, and reported, fled, analysis is marginal, or Xti ported. although some deficiencies reporting is late.
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b. Key vacant positions are b. Key vacant positions are b. Key positions are left vacant filled on a priority basis. usually filled in a reason- for extended periods.
able time.
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c. Expertise is available and c. Expertise is usually avail- c. Expertise is difficult to ac- staffing is ample, as indi- able and staffing is ade- cess or at times is not avail- cated by control over back- quate, as indicated by occa- able, and staffing is weak or log and overtime. sional backlogs or use of minimal, as evidenced by overtime. large backlogs or use of t%)
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d. Staffing has sufficient depth d. Staffing has sufficient depth d. Staffing lacks depth.
and minimizes the impact of in most cases. 0.
individual resource losses.
e. Licensee resources are e. licensee resources are gen- e. licensee resources are re- effectively applied in a erally effective. stricted, limiting the effec- o3t timely manner. tiveness of programmatic ta".
and/or corrective action.
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work, as evidenced by few of work, as evidenced by and staffing to the under- personnel errors. personnel errors or numer-
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mented with dedicated re- poorly defined or ineffec- V-9.
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c. Inadequate training is not a c. Inadequate training is not a 1 primary root cause of major c. Inadequate training is a pri- ::J
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primary root cause of major mary root cause for signifi- 51 or minor problems. problems. C:
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problems. %_-1 d. Procedures and policies are d. Procedures and policies are followed. Some isolated de-. d. Procedures and policies are i1 rarely violated. occasionally violated, indi-
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Handbook 8.6 Exhibits I
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32 Approved: (Draft 08/10/92)
-4- Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Exhibits Exhibit 4 Evaluation Matrix for Construction Phase Functional Areas
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Systematic Assessmer' of Licensee Performance (SALP)'-"
Handbook 8.6 Exhibits Exhibit 5
[Initial or Final] SALP Report U.S. Nuclear Regulatory Commission Region [number]
Systematic Assessment of Licensee Performance
[Inspection Report Number]
[Name of Licensee]
[Name of Facility and Docket Number]
[Assessment Period]
34 Approved: (Draft 08/10/92)
Systematir'Assessment of Licensee
- Performance (SALP)
Handbook 8.6 Exhibits Exhibit 5 (continued)
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) Program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information. The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of its facility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on [date], to review the observations and data on performance, and to assess licensee performance in accordance with NRC Manual Directive 8.6, "Systematic Assessment of Licensee Performance (SALP)" (formerly MC 0516).
This report is the NRC's assessment of the licensee's safety performance at [name of facility] for the period [date] through [date].
The SALP Board for [name of facility] was composed of:
[list names and titles of SALP Board members]
II. SUMMARY OF RESULTS
A. Overview
[The ratings assigned to the individual functional area are only one aspect resulting from the SALP process. The SALP Board is expected to assess each functional area in such a manner that the SALT Board discussion focuses on understanding the reasons for the observed performance. The attributes and assessment criteria provided in Handbook 8.6, Part II, "Evaluation Criteria," should be used to develop a uniform and consistent approach. After assessing all of the functional areas, the SALP Board is expected to discuss commonalities, if any, among the functional areas. This process of reviewing the summary results from the standpoint of identifying common underlying reasons for the licensee's performance is the basis for the overview. The overview should also note functional areas in which ratings have changed since the previous period and discuss the reasons for the changes. The overview should not be a summary statement of the individual functional areas; rather, the overview is intended to be an executive summary with a synopsis of the underlying reasons in the view of NRC
managers for both good and poor licensee performance as well as for changes in Approved: (Draft 08/10/92) 35
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Exhibits-' _
Exhibit 5 (continued)
II. SUMMARY OF RESULTS (continued)
performance. With regard to poor performance, the overview developed somewhat specific so that the licensee may be fully aware of the should be increased utility management attention is required. The overview areas in which should any recommendations assigned to functional areas. In addition, also include performance category ratings should be provided, as indicated below. a table of To emphasize topics for consideration beyond the specified functional Office of Nuclear Reactor Regulation (NRR) may identify selected areas, the topics as part of the overview. These selected topics will be addressed by all for inclusion a defined period, and the summary results will be included as a part SALP Boards for of the overview.]
[Functional area] [Rating last period] [Rating this period] [Trend, the trend definition as a footnote] if any, and provide B. Other Areas of Interest
[Provide an overview of licensee performance in each topic area. These determined by the Director, NRR, and/or the regional administrator.]topic areas are III. PERFORMANCE ANALYSIS
A. [State the functional area being discussed] [Briefly state the wvere performed in this area] inspections that
1. Analysis
[This analysis should concentrate on the licensee's performance with respect to the evaluation criteria and attributes. This section should not necessarily tabulate the information and data that contribute to the analysis; rather, reiterate or summary of the supporting rationale. The analysis should be concise it should be a communicate the NRC's assessment of licensee performance. The yet should fully functional area analysis should reflect the applicable NRC resources length of each expended and the licensee activities during the assessment period. Any appropriate information should be provided in Section IV of this report. Licensee performance and data discussed in light of the evaluation criteria and associated attributes should be both completeness and to compare licensee performance across functional to ensure analysis is intended to be sufficiently diagnostic to provide a rationale areas. The NRC resources and to provide meaningful feedback to the licensee's for allocating management.]
36 Approved: (Draft 08/10/92)
I
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Exhibits Exhibit 5 (continued)
III. PERFORMANCE ANALYSIS (continued) -
2. Performance Rating
[Provide the performance rating (Category 1, 2, or 3) for each functional area considered. If appropriate, include a trend assessment (improving or declining).]
3. Recommendations
[Include any general or specific NRC recommendations pertaining to either the licensee's management or the level of NRC inspection activities in a functional area.
Note that even in the absence of a recommendation to vary the inspection effort, the regional office may do so at its discretion on the basis of appropriate NRC
management directives.]
IV. SUPPORTING DATA AND SUMMARIES
A. Major Licensee Activities
[Provide a factual outline of major licensee activities, such as major outages, power limitations, important license amendments, and significant modifications.]
B. Direct Inspection and Review Activities
[Provide a factual summary of major direct inspection and review activities performed by resident inspectors, region-based staff, and headquarters staff in each functional area. This is not intended to be a summary of each inspection or review performed but rather of those that had a significant effect on the results discussed in Section III of this report.]
C. Other
[Discuss any other issues, at the discretion of the SALP Board.]
Approved: (Draft 08/10/92) 37
Systematic Assessmeijf Licensee Performance (SALP)
Handbook 8.6 Exhibits a
Exhibit 6 Sample SALP Board Report Revision Sheet PAGE LINE NOW READS SHOULD READ
5 2 Two of the three One of the three plant plant trips this as- trips this assessment sessment period period resulted from resulted from in- incorrect operation of correct operation the feedwater regula- of the feedwater tion bypass valves.
regulation bypass Another resulted valves. from insufficient root cause determination of the failure of a sole- noid valve in the same system.
Basis: The SALP incorrectly stated the cause of two reactor trips incorrect operation of the feedwater regulation bypass valves. was SALP has been changed to reflect the actual cause of the two The trips. plant
38 Approved: (Draft 08/10/92)
Systematic Assessment of Licensee Performance (SALP)
Handbook 8.6 Exhibits Exhibit 7 Sample Revised Page The licensee's corrective action has not been effective in all cases, as indicated by repetition of valve operation problems noted in the previous SALP. One of the three plant trips this assessment period resulted from incorrect operation of the feedwater regulation bypass valves. Another resulted from insufficient root cause determination of the failure of a solenoid valve in the same system. The previous SALP report noted two cases of incorrect operation of the same valves.
Plant operators exhibited excellent control of transient plant conditions, reflecting high-quality training. Good response by control room operators was noted following an inadvertent trip of the turbine electrohydraulic control system pumps, inadvertent tripping of a circulating water pump, and failure of the cold-leg temperature instrument. These responses averted two plant trips and unnecessary plant transients. During a surveillance test on a pressurizer pressure instrument, manual control of plant pressure was necessary. Rehearsal of this operation on the plant simulator and pre-evolution planning for potential transients during the test enable operators to expeditiously respond to a spurious opening of the spray valve.
Operator attention to detail and adherence to procedures in performance of repetitive or routine activities exhibited problems. Weaknesses were noted in the thoroughness of periodic panel walkdown inspections by operators. For example, on one occasion a valve misalignment affecting service water operability, identifiable from the main control board, went undetected for four operating shifts.
Additional problems with effective equipment status tracking were noted. Multiple control rod misalignment events occurred during the unit startup, reflecting inattention by the operators. On several occasions, ineffective communications within the control room, or between the control room operators and personnel in the plant, contributed to events. The consistency of shift turnover, walkdown inspections, and equipment status tracking improved during the later portion of the period by formalizing the turnover process via an operations department procedure and by the use of a plant status list.
The licensed operator requalification program was evaluated this assessment period with excellent results. NRC examiners noted excellent control of transient conditions by the senior reactor operators. One minor programmatic concern was identified and promptly corrected. The licensee provides sufficient time and excellent training facilities to effectively train and requalify licensed and non-licensed operators. Staffing levels were excellent, as evidenced by fully staffed six-crew rotation and the availability of additional licensed operators for planned heavy workload periods. Overtime was well controlled and not excessive.
5A
39 IT 39 Approved: (Draft 08/10/92)
systematic Assessment of Licensee Performance (SALP) -
Handbook 8.6 Exhibit _
I
Exhibit 8 Sample Original Page V
c
'nsee's corrective action has not been effective in all cases, as indicated by of valve operation problems noted in the previous SALP. Two of the trips this assessment period resulted from incorrect operation of the
- ilation bypass valves. The previous SALP report noted two cases of
. -on of the same valves.
PA. bited excellent control of transient plant condi tions, reflecting high Good response by control room operators vvas noted follow. \ trip of the turbine electrohydraulic contro 1system pumps, inadvertu irculating water pump, and failure of the cold-leg temperata .else responses averted two plant trips aand unnecessary plant trans'e, eillance test on a pressurizer pressu:re instrument, manual controA was necessary. Rehearsal of this operation on the plant simulator a. Tlanning for potential transients during the test enable operators tL \ ond to a spurious opening of*the spray valve.
Operator attention to v p -ice to procedures in perfoi -mance of repetitive or routine acti. nblems. Weaknesses wer *enoted in the thoroughness of periodic p. pections by operators. For example, on one occasion a valve misa. v service water operaability, identifiable from the main cont. % 'ndetected for four operating shifts.
Additional problems with effectiv C, 's tracking were noted. Multiple control rod misalignment events oc% + unit startup, raeflecting inattention by the operators. On sevt. ffective corn munications within the control room, or between tht. ,rators an d personnel in the plant, contributed to events. The con:. mover, walkdown inspections, and equipment status tracking i. . 'he lateer portion of the period by formalizing the turnover process via narltment procedure and by the use of a plant status list.
The licensed operator requalification program was K -ssment period with excellent results. NRC examiners noted excellen. 'ent conditions by the senior reactor operators. One minor Z -cern was identified and promptly corrected. The licensee providesX.
excellent training facilities to effectively train and requalify J. \e non-licensed operators. Staffing levels were excellent, as evio, six-crew rotation and the availability of additional licensed opera \ fed heavy workload periods. Overtime was well controlled and not ex.
5
40 Approved: (Draft 08/10/92)
f -- it ;<V Am l:-
- 2 - September 4, 1992 This generic letter contains no information collection requirements and therefore is not subject to the requirements of the Paperwork Reduction Act of
1980 (44 U.S.C. 3501 et seq.).
- Please contact Cornelius Holden (301-504-1037) if you have any questions about this matter. No specific licensee actions are required.
Sincerely, Original signed:
James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:
As stated DISTRIBUTION:
Central Files LPEB R.F.
CHolden AMendiola GGZech COThomas JWRoe GMarcus WTRussell JGPartlow NRC PDR
t See previous concurrence OFC LPEB:DLPQ SC:LPEB:DLPQ TECH EDITOR BC:LPEB:DLPQ DD:DLPQ:NRR
NAME CHolden:jp AMendiola JMain GGZech COThomas DATE 8/ 27/92* 8/ 27/92* 8/28/92* 8/31/92* 8/31/92*
)FC D:DLPQ:NRR BC:AGCB:DOEA:NRR ADT:NRR ADPR:NRR oaAfin qAME JWRoe GMarcus WTRussell JGPartlow JATE I 8/31/92* 8/31/92* Ioq/0l 12*
_ . - I , _, 9/4 /92 OFFICIAL RECORD COPY
Document Name: SALPWRKS.GEN