NRC Generic Letter 1992-05
Spi RE(440UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555September 4, 1992TO:ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FORNUCLEAR POWER REACTORS
SUBJECT: NRC WORKSHOP ON THE SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE(SALP) PROGRAM -GENERIC LETTER 92-05The U.S. Nuclear Regulatory Commission (NRC) is announcing its plans toconduct a workshop on the SALP Program on September 29, 1992. The workshopwill be held from 9:00 a.m. to 5:00 p.m. at the Holiday Inn Crowne Plaza, 1750Rockville Pike, Rockville, Maryland 20850, telephone (301) 468-1100.The NRC SALP Program is the Agency's integrated effort to collect and evaluateavailable agency insights and information in a structured manner to assess andbetter understand licensee performance. The NRC is interested in obtainingcomments from the public and industry on its proposed changes to the SALPProgram. A copy of the draft Management Directive 8.6, "Systematic Assessmentof Licensee Performance," is enclosed for information only. Once approved,Management Directive 8.6 will replace the current program guidance containedin Manual Chapter 0516, "Systematic Assessment of Licensee Performance." Thestaff will consider comments received during this workshop, and those receivedseparately, in preparing its final recommendations to the Commission forchanges to the SALP Program. The NRC published a notice of this workshop inthe Federal Reqister on August 28, 1992.The workshop will consist of a plenary session, break-out sessions, and asummary session. During the plenary session, NRC representatives will discussproposed changes to the SALP Program. This will be followed by break-outsessions in which attendees may ask questions about the SALP Program and makecomments or suggestions for improving the SALP Program. The workshop willconclude with a session to summarize the issues discussed in each of thebreak-out sessions.Persons planning to attend the workshop should complete a copy of the enclosedregistration form and send it to Mr. Cornelius Holden, M/S 10-A-19, Office ofNuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington,D.C. 20555.Interested parties unable to attend this workshop may submit written commentsby September 29, 1992. Comments received after this date will be consideredif it is practical to do so, but the Commission can ensure consideration onlyfor comments received on or before this date. Submit written comments to theChief, Rules and Directives Review Branch, U.S. Nuclear Regulatory Commission,Washington D.C. 20555.9209040202
-2 -September 4. 1992This generic letter contains no information collection requirements andtherefore is not subject to the requirements of the Paperwork Reduction Act of1980 (44 U.S.C. 3501 et seq.).Please contact Cornelius Holden (301-504-1037) if you have any questions aboutthis matter. No specific licensee actions are required.
Sincerely,mes G. PartlowAssociate Director for ProjectsOffice of Nuclear Reactor Regulation
Enclosure:
As stated REGISTRATION FORMUNITED STATES NUCLEAR REGULATORY COMMISSIONSYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE PROGRAMHOLIDAY INN CROWNE PLAZA HOTELSEPTEMBER 29, 1992NAMETITLECOMPANY/ORGANIZATION.ADDRESSTELEPHONE NUMBERSUGGESTED TOPICS RELATED TO THE SALP PROGRAM TO BE CONSIDERED FOR DISCUSSION:Send registration form to:Cornelius HQldenM/S 10 A 19Office of Nuclear Reactor Regulation-U. S. Nuclear RegulatoryCommissionWashington, D.C. 20555 LIST OF RECENTLY ISSUED GENERIC LETTERSGenericLetter No.SubjectDate ofIssuance08/19/92Issued ToALL BWR LICENSEESFOF OPERATINGREACTORS92-04RESOLUTION OF THE ISSUESRELATED TO REACTOR VESSELWATER LEVEL INSTRUMENTATION INBWRs PURSUANT TO IOCFR50.54(F)90-02SUPPLEMENT 187-02SUPPLEMENT 1ALTERNATIVE REQUIREMENTSFOR FUEL ASSEMBLIES IN THEDESIGN FEATURES SECTION OFTECHNICAL SPECIFICATIONSSAFETY EVALUATION REPORTNO. 2 ON SQUG GENERICIMPLEMENTATION PROCEDURE,REVISION 2.07/31/9205/22/92ALL LWR LICENSEESAND APPLICANTSALL USI A-46LICENSEES WHOARE SQUG MEMBERS92-03COMPILATION OF THE CURRENTLICENSING BASIS: REQUESTFOR VOLUNTARY PARTICIPATIONIN PILOT PROGRAM03/19/92ALL NUCLEAR POWERPLANT APPLICANTSAND LICENSEES92-01REVISION 1REACTOR VESSEL STRUCTURALINTEGRITY, 1OCFR5O.54(f)3/06/92ALL HOLDERS OF OPLICENSES OR CONST.PERMITS FOR NUCLEARPWR PLANTS (EXCEPTYANKEE ATOMIC FORYANKEE NUC PWR STA.)92-02RESOLUTION OF GENERICISSUE 79, UNANALYZED REACTORVESSEL (PWR) THERMAL STRESSDURING NATURAL CONVECTIONCOOLDOWN03/06/92ALL HOLDERSLICENSES OFPERMITS FOROF OPCONST.PWRs92-01REACTOR VESSEL STRUCTURALINTEGRITY, 1OCFR50.54(f)NOT ISSUEDRevisionListedAboveALL HOLDERS OF OPLICENSES OR CONST.PERMITS FOR NUCLEARPWR PLANTS (EXCEPTYANKEE ATOMIC FORYANKEE NUC PWR STA.)* 89-10SUPPLEMENT 4CONSIDERATION OF VALVEMISPOSITIONING IN BWRs02/14/92ALL LICENSEES OF OPNUC PWR PLANTS ANDHOLDERS OF CONSTRUCTIONPERMITS OR PWR PLANTS* NOTE: 89-10 Supp. 4 -Accession No. 9202070037 has been changed to 920225031 Systematic Assessment ofLicensee Performance(SALP),E " :eK,.'c.z;i * :Dire ctive(FormerlyMC 0516)8.6DRAFTt -I I .1. I- I 11 .-., .-Y-.- :-- %.- ... :--- .: -.- , '... , ; " ., -qll ..: I- ... : ;.. " -, '-' : , -'- 1. : -, -'-....I.- ... I -, , , ., ..., , .... ..., , ., '. .,., ..., .I :1. :-, : ...% ., .. .: ..-% ., .. ... ., , " .,, .,. ........ "'. ... ;,, ..... --...... -.. -1 .......... 1. , 1.-..... .-.: ., , ,, .". -': -r -..-. ; ..-: ...... -- .% , a. .. .. ... .... :. ., , -.'- --., .:. .....:.. .:I .. ...o- .:,. ..... ::, , ... .:,: ..... ..- .-,.. ... ... ........... ...
Systematic ssessment of LicenseePerformance (SALP)Directive 8.6ContentsPolicy.................................................................Objectives ............................................................-Organizational Responsibilities and Delegations of Authority ...........The Executive Director for Operations (EDO) ............................The Director, Office of Nuclear Reactor Regulation (NRR) .................Office Directors....................................................Regional Administrators. ..............................................Applicability ....................................................licensees ...........................................................Employees ..........................................................Handbook .............................................................I1222224444Approved: (Draft 08/10/92)iT U. S. Nuclear Regulatory Co. .mission.° Volume: 8 Licensee Oversight Programs NRRSystematic Assessment of LicenseePerformance (SALP)Directive 8.6Policy(8.6-01)This directive and handbook govern the scope, objectives, authorities,responsibilities, and basic requirements of the Systematic Assessmentof licensee Performance (SALP) Program. The SALP is an integratedagency effort to collect and evaluate available agency insights, data,and other information on a plant/site basis in a structured manner inorder to assess and better understand the reasons for a licensee's per-formance. The manner in which a licensee meets regulatoryrequirements and the degree to which a licensee seeks to improveperformance are both measures of a licensee's commitment to nuclearsafety and plant reliability.Objectives(8.6-02)* To conduct an integrated assessment of licensee performance fromthe findings and conclusions of the NRC during an assessmentperiod in a manner that highlights strengths and weaknesses. (021)* To provide a vehicle for meaningful dialogue with the licenseeregarding its performance based on the insights gained fromlong-term synthesis of NRC observations. (022)* To assist NRC management in making sound decisions regardingallocation of NRC resources used to oversee, inspect, and assesslicensee performance. (023)Approved: (Draft 08/10192)I Systematic Assessmerjf Licensee __Performance (SALP)Directive 8.6Organizational Responsibilities andDelegations of Authority(8.6-03)The Executive Director forOperations (EDO)(031)Provides oversight for the activities described in this directive andhandbook.The Director, Office of NuclearReactor Regulation (NRR)(032)* Implements the requirements of this directive within NRR. (a)* Monitors the SALP process. (b)* Evaluates and develops SALP policy, criteria, andmethodology. (c)* Assesses the uniformity and adequacy of the implementation of theprogram. (d)Office Directors(033)* Implement the requirements of this directive within theirrespective offices. (a)* Confer with the Director, NRR, and inform the Deputy ExecutiveDirector for Nuclear Reactor Regulation, Regional Operations,and Research (DEDR) when contemplating significant deviationsfrom the requirements or guidelines of this directive. (b)Regional Administrators(034)* Implement the requirements of this directive within theirrespective regions. (a)2 Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Directive 8.6Regional Administrators(034) (continued)* Confer with the Director, NRR, and inform the Deputy ExecutiveDirector for Nuclear Reactor Regulation, Regional Operations,and Research (DEDR) when contemplating significant deviationsfrom 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 theadequacy of the licensee's commitments to improveperformance. (ii)-Issue the final SALP report. (iii)* Direct reallocation of regional inspection resources, as and whenappropriate. The regional administrator should consider reducingthe level of inspection effort for SALP Category 1 functional areas,consider maintaining the level of inspection effort for Category 2functional areas, and consider increasing the level of inspectioneffort for SALP Category 3 functional areas. (d)* Authorize changes and the basis for the changes to initial SALPreports, as appropriate. (e)* Establish a schedule, establish NRC participation, and determine asite for a meeting with the licensee to ensure mutual understandingof the issues discussed in the SALP report. (f)* Suspend the SALP process for any plant that is placed on theCategory 3 list of problem facilities as a result of the SeniorManagement Meeting process. The SALP process should notresume until the facility is removed from this category. (g)* Assess the uniformity and adequacy of regional implementationof the SALP Program. Provide to the Director, NRR,recommendations for improving the SALP Program. (h)
Systematic Assessmeh-f LicenseePerformance (SALP)Directive 8.6Applicability(8.6-04)Licensees(041)aThis program applies to all licensees of power reactors with operatinglicenses or construction permits.Employees(042)The provisions of this directive and handbook apply to and must befollowed by NRC headquarters and regional personnel.Handbook(8.6-05)Major components of the SALP Program are specified inHandbook 8.6.4 Approved: (Draft 08/10/92)
Systematic Assessment ofLicensee Performance(SALP)SS.'.'S. .:;'.,>,..: .. :SX.:>:.:.:.:.i :.: ;'Ss>be^:tfiU:S.,:wx.:> .^.;A.,:. *Handbook(Formerly f jAppendix 0516) 8. 6 Systematit ssessment of LicenseePerformance (SALP)Handbook 8.6 Parts I -IIIContentsIntroduction .........Part IImplementing Instructions for the SALP Program ...................Evaluation Frequency (A) ...........................................Evaluation Process (B) .............................................Functional Areas (C) ..............................................Operating Phase Reactors (D) ........................................Plant Operations (1) ............................................Maintenance (2) ................................................Engineering (3) ................................................Plant Support (4) ...............................................1334566677Other Functional Areas (as appropriate) (5)........................ 7Construction Phase Reactors (E) .............................Soils and Foundations (1) ..........................'Containment, Major Structures, and Major Steel Supports (2)Piping Systems and Supports (3) .........................Mechanical Components (4) .............................Auxiliary Systems (5) ..................................Electrical Equipment and Cables (6) ......................Instrumentation (7) ....................................Engineering and Design Change Control (8) ...............Other Functional Areas (as appropriate) (9) ...............Evaluation Criteria (F) .............................-Performance Ratings (G) ...................................Performance Trend (H) .............................;....................77......... .8....................................................................................................88999910101012Part IIEvaluation Criteria..................................................13Approved: (Draft 08/10/92)i Performance (SALP)Handbook 8.6 Parts I -IIIContents (continued)Part IIIImplementation of the SA.LP .................... 14Assessment by the SALP Board (A) ...14Preparation for the SALP Board Meeting (1) ..14SALP Board Meeting (2) ...15Issuance of the Initial Report (B) ...17Meeting With the licensee (C) ...18General (1) ...18Meeting Preparation (2) ..19Licensee Meeting (3) ...19Format and Content of the SAyP Report D) ...20General (1) ...20Report Format and Content (2) ...21Final SALP Report (E) ...21General (1) ...21Specifics of the Final SALTP Report (2) ...21Changing the Initial SALP Report (3) .. 22Exhibits1. SALP Evaluation Process .232. Evaluation Criteria and Attributes for Assessment of Licensee Performance ..243. Evaluation Matrix for Operating Phase Functional Areas .324. Evaluation Matrix for Construction Phase Functional Areas .335. SALP Report [Initial or Final] .346. Sample SALP Board Report Revision Sheet .......................... 387. Sample Revised Page .398. Sample Original Page .40;; ,Approved: (Draft 08/10/92)I Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 IntroductionIntroductionThe SALP process is used by the NRC to synthesize its observations ofand insights into a licensee's performance and to identify commonthemes or symptoms. Thus, the NRC needs to recognize andunderstand the reasons for a licensee's strengths as well as weaknesses.Unacceptable performance is addressed through various NRCprograms and policies, and the implementation of these activitiesshould not be delayed to await the results of a SALP assessment. (A)The primary product of the SALP process is the SALP report, which isaddressed in Part III of this handbook. The results of the SALP processas documented in the SALP report are used to express NRC seniormanagement's observations and judgments on the licensee'sperformance. The SALP should not be limited to weaknesses and isnot intended to propose problem resolutions or solutions. Thelicensee's management is responsible for ensuring plant safety andestablishing effective means to measure, monitor, and evaluate thequality 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, andprovides resources for safe plant operations and (2) how effectivethese actions are. Performance indicators should not be a factor injudging the effectiveness of or rating a particular functional area.Although indicators may correspond in varying degrees to SALPfunctional areas, the Performance Indicator Program is separate anddistinct from -the SALP Program. Indicators such as failure of a plant'ssafety systems or frequent forced outages because of equipmentfailures may be symptomatic of safety problems. Thus, events andfailures captured by the program may appear in SALP discussions andreports. However, these SALP references are to be based on theunderlying causes of poor performance and not on the results of thePerformance 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 licenseePerformance (SALP)Handbook 8.6 Intro, -tionIntroduction (continued)As a result, the SALP process emphasizes understanding the reasonsfor a licensee's performance in identified functional areas and onsharing this understanding with the licensee and the public. The SALPprocess is intended to provide meaningful feedback to a licensee'smanagement and to be sufficiently diagnostic to provide a rationale forallocating NRC resources. (D)2 Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IPart IImplementing Instructions for theSALP ProgramEvaluation Frequency (A)The NRC will normally review and evaluate each power reactorlicensee that possesses an operating license or a construction permit atleast every 18 months, except in the following instances: (1)* When a new operating license is issued, two consecutive SALPevaluations should be scheduled at approximately 12-monthintervals. The first of these two evaluations should be scheduled forcompletion approximately 12 months after the low-power license isissued. The second of these two evaluations should be completedapproximately 12 months later. Following completion of these twoevaluations, a determination should then be made on whether toplace the licensee on a normal SALP schedule. (a)* When the regional administrator determines that the performanceof a particular utility or facility warrants a more frequentevaluation, the normal SALP frequency may be increased. Forexample, in the case of a licensee that was assigned a Category 3performance rating in one or more functional areas during theprevious evaluation, the period between SALP evaluations may bereduced to about 12 months. The regional administrator may electto conduct additional management meetings with the licensee tomonitor the licensee's self-assessment efforts and performanceprogress following a SALP with poor ratings, rather than or inaddition to reducing the length of the assessment period. (b)* The region may reduce the SALP cycle length to less than18 months in order to avoid schedular conflicts. (c)Approved: (Draft 08/10/92)I3 reriormance (SALP)Handbook 8.6 Part IEvaluation Frequency (A) (continued)* The assessment period may be extended to a maximum of24 months, with the concurrence of the Director, NRR, when aplant meets the screening criteria established for superiorperformance recognition by the NRC Senior ManagementMeeting for two consecutive SALP evaluation cycles. (d)* When circumstances warrant, the normal SALP frequency may besuspended. Infrequent SALPs may be indicated for plants inextended shutdowns, extended outages, or decommissioning, andsome aspects of the SALP evaluation may not be applicable. Plantsin these circumstances are typically covered by separate assessmentand readiness review programs. In these cases, the regionaladministrator shall confer with the Director, Office of NuclearReactor Regulation (NRR), and document the basis forsuspending the normal SALP frequency. (e)* In particular, the SALP process should be suspended for any plantthat is shut down and requires Commission (not staff)authorization to restart. As a part of a restart review process, anungraded evaluation of performance and trends in the SALPfunctional areas may be performed. (f)For licensees that operate plants at more than one site, or that operateplants at one site that may be in different stages, such as theconstruction stage, the preoperational stage, or power ascension froman extended outage, an individual assessment will usually beperformed. (2)For licensees that operate plants at one site that are of significantlydifferent design, the regional administrator will determine ifindividual assessments are necessary to capture and communicate theNRC's assessment of licensee performance for these plants. Forlicensees that operate plants at a multiple-unit site, one assessment fora common functional area may be appropriate. (3)For licensees of multiple facilities such as Duke Power Co., TennesseeValley Authority, and Commonwealth Edison, each site must have aseparate SALP report. (4)Evaluation Process (B)The evaluation process, illustrated in Exhibit 1 of this handbook, issummarized as follows: (1)4 Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IEvaluation Process (B) (continued)* Conduct a SALP using the evaluation criteria contained in Part IIof this handbook. (a)* Issue the SALP report. (b)* Conduct a public meeting with the licensee's management todiscuss the assessment. Normally the meeting will be conducted onsite or in the vicinity of the site when feasible to foster morewidespread understanding of the NRC's views. (c)* Consider any written response received from the licensee. A finalSALP report will be issued and will include the written responsereceived from the licensee and any changes to the SALP reportbased on the regional administrator's review of the licensee'sresponse. (d)General guidance regarding the implementation of the SALP isprovided in Part III of this handbook. Specific guidance for theimplementation and conduct of the SALP process is contained in theoperating 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. Theevaluation criteria and associated attributes against which thefunctional areas are to be evaluated are provided in Part II of thishandbook. Note that it is inappropriate to refer to PerformanceIndicator Program results in forming a SALP rating. (1)The category ratings assigned to individual functional areas are onlyone aspect of the SALP process. The SALP Board is expected to assesseach functional area in such a manner that the discussion focuses onunderstanding the reasons for the observed performance. Theattributes and assessment criteria provided in Part II of this handbookshould be relied on to develop a uniform and consistent approach.After assessing all the functional areas, the SALP Board is expected todiscuss any commonalities among the functional areas. This process ofreviewing the summary results from the standpoint of identifyingcommon underlying reasons for the licensee's performance is the basisof the "Overview" section of the report. The overview should also noteApproved: (Draft 08/10/92)
_- x:1 yurmlanct 3A1,r)Handbook 8.6 Part IFunctional Areas (C) (continued)functional areas in which ratings have changed since the previousperiod and discuss the reasons for these changes. (2)To emphasize topics for consideration beyond the specified functionalareas, NRR may include selected topics as part of the overview. Thesetopics will be addressed by all SALP Boards for aldefined period, andthe summary results will be presented as part of the overview. (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 ofactivities directly related to operating a plant. It includes activities suchas plant startup, power operation, plant shutdown, and system lineups.Thus, it includes activities such as monitoring and logging plantconditions, normal operations, response to transient and off-normalconditions, manipulating the reactor and auxiliary controls, controlroom professionalism, and interface with activities that supportoperations. It also includes initial and requalification training oflicensed operators.Maintenance (2)This functional area includes all activities associated with eitherdiagnostic, predictive, preventive, or corrective maintenance of plantstructures, systems, and components, or maintenance of the physicalcondition of the plant. It also includes conduct of all surveillance(diagnostic) testing activities, as well as all inservice inspection andtesting activities. Testing activities also include instrumentcalibrations; equipment operability tests; post-maintenance,post-modification, and post-outage testing; containment leak ratetests; special tests; inservice inspection and performance tests ofpumps and valves; and all other inservice inspection activities.6 Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IOperating Phase Reactors (D) (continued)Engineering (3)This functional area addresses the adequacy of technical andengineering support for'all plant activities. It includes all licenseeactivities associated with design control; the design and installation ofplant modifications; engineering and technical support for operations,outages, maintenance, testing, surveillance, and procurementactivities; configuration management; design basis reconstitution; andsupport for licensing activities related to amendment, exemption, andrelief request.Plant Support (4)This functional area covers all activities related to plant supportfunctions, including radiological controls, emergency preparedness,security, housekeeping controls, chemistry, and fire protection. Itincludes all activities associated with occupational radiation safety,radioactive waste management, radiological effluent control andmonitoring, transportation of radioactive materials, licenseeperformance during emergency preparedness exercises and actualevents that test emergency plans, emergency plan notifications,interactions with onsite and offsite emergency response organizationsduring exercises and actual events, and safeguards measures thatprotect 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 toaddress shutdown operations in lieu of plant operations. For readinessassessments, SALP Boards may need to consider activities that takeplace 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 andfoundations related to the construction of the ultimate heat sink andApproved: (Draft 08/10/92)7 Systematic Assessment of LicenseePerformance (SALP, .Handbook 8.6 Part IConstruction Phase Reactors (E) (continued)Soils and Foundations (1) (continued)major structures. Specifically, this area covers, as applicable, subgradeinvestigation and preparation, fill materials and compaction,embankments, foundations and associated laboratory testing, andrelated instrumentation and monitoring systems.Containment, Major Structures, and Major Steel Supports (2)This functional area includes all activities related to the structuralconcrete and steel used in the containment (including the basemat),major structures, and major steel equipment supports. It covers allaspects of structural concrete (e.g., reinforcing steel; concretebatching, delivery, placement, in-process testing, and curing; linerplate 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, reactorcoolant 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 thelicensee's safety analysis report (SAR) that affect the safe operation ofthe plant. It includes those activities and quality checks such asfabrication, installation, configuration, welding, nondestructiveexamination, and preservice inspection necessary to ensurecompliance with the applicable codes and other requirementsspecified in the safety analysis report, specifications, andimplementing procedures.Mechanical Components (4)This functional area covers mechanical components such as pressurevessels; reactor vessel internals, pumps, and valves located in, andattached to, the piping systems described under the precedingfunctional area. The primary emphasis is on discrete componentsrather than piping or systems.8 Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IConstruction Phase Reactors (E) (continued)Auxiliary Systems (5)This functional area includes those auxiliary systems in the nuclearfacility that are essential for the safe shutdown of the plant or theprotection of the health and safety of the public. It includes systemssuch as the heating, ventilation, and air conditioning; radwaste; fireprotection; 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 asmotors; transformers, batteries, emergency diesel generators, motorcontrol centers, switchgear, electric raceways, cable (power, control,and instrument), circuit breakers, relays, and other interrupting andprotective devices.Instrumentation (7)This functional area covers instrument components and systems thatare designed to measure, transmit, display, record, and/or controlvarious plant variables and conditions. The reactor protection systemand the engineered safety features actuation system are examples ofcovered plant systems. Also included are devices such as sensors,transmitters, signal conditioners, controllers, and other actuatingdevices, 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 andengineering support for all plant activities. It includes all licenseeactivities associated with the design of the plant; engineering andtechnical support for maintenance, testing, surveillance, procurement,and preoperational, startup, and operational activities; training; andconfiguration management, including maintaining design bases andsafety margins; and licensee activities related to exemption and reliefrequests.Approved: (Draft 08/10/92)9 Systematic Assessment of LicenseePerformance (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 foreither operating phase reactors or construction phase reactors shouldbe selected, as appropriate. For reactors in the startup phase,functional areas listed for operating phase reactors should be used.Evaluation Criteria elicensees will be evaluated in the functional areas described above,using the following evaluation criteria. Part II of this handbookdescribes a number of attributes for each evaluation criterion andprovides guidance on using these criteria to assign a performancerating. 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 ofcorrective 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 licenseeactivities and safety performance in selected functional areas.Licensees assigned a Category 1 rating in a functional area have clearlydemonstrated superior performance, which may justify somerelaxation in NRC oversight. Conversely, licensees assigned aCategory 3 rating in a functional area are of concern to NRC, and NRCwill consider additional interaction with and oversight of thelicensee. (1)10 Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IPerformance Ratings (G) (continued)The functional area being evaluated may have some attributes thatmerit a Category I rating and others that merit either a Category 2 or aCategory 3 rating. The final rating for each functional area will be acomposite rating of the attributes based on a knowledgeable balancingof experiences and safety significance by senior NRC managers andstaff. Statistical or numerical balancing is inappropriate. (2)The following performance categories are used to rate licenseeperformance: (3)* Category 1. Licensee management attention to and involvement innuclear safety or safeguards activities resulted in a superior level ofperformance. (a)* Category 2. Licensee management attention to and involvement innuclear safety or safeguards activities resulted in a good level ofperformance. (b)* Category 3. licensee management attention to and involvementin nuclear safety or safeguards activities resulted in an acceptablelevel of performance. However, because the margin tounacceptable performance in important aspects is small, NRC andlicensee attention is required. (c)* Category N. Insufficient information exists to support anassessment of licensee performance. These cases include instancesin which a rating cannot be developed because of insufficientlicensee activity or insufficient NRC inspection. This category isnormally 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 butshould be taken at the time the unacceptable action or event occurs. Inthis regard, the SALP process can assist NRC management byproviding perspective; but it is not a substitute for effectiveenforcement action. When licensees cannot consistently meetregulatory requirements, the affected plants will be considered forescalated enforcement action, including enforcement resulting inshutdown. (4)Approved: (Draft 08/10/92)11 rerlormance tBALr)Handbook 8.6 Part IPerformance Trend (H)NRC should examine licensee performance during the assessmentperiod to determine whether a trend exists. Of particular interest arethose licensees with a Category 3 performance rating and a decliningtrend. 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 ReactorRegulation, Regional Operations,' and Research; and the regionaladministrator. (1)The performance trend should be determined selectively and shouldbe reserved for those instances in which it is necessary to focus theattention of NRC and the licensee on an area with a decliningperformance trend, or to acknowledge an improving trend in licenseeperformance. (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 mayresult in a future change in category rating. (a)* Declining. licensee performance was determined to be decliningduring the assessment period and continuation of the trend mayresult in a future change in category rating. (b)12Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IIPart IIEvaluation CriteriaNRC assesses licensee performance by applying seven evaluationcriteria to each functional area. Exhibit 2, "Evaluation Criteria andAttributes for Assessment of Licensee Performance," lists theattributes associated with each criterion. (A)The seven criteria and their associated attributeswill aid the NRC staffin understanding and evaluating licensee performance by identifyingthe causes and factors associated with Categories 1, 2, and 3. It is notintended that consideration of these attributes influence establishedagency programs. For example, it is not intended that the staff performspecific inspections to evaluate attributes. It is expected that during theimplementation of established programs, the staff will observe manyof the attributes that describe performance. Awareness andconsideration of these attributes should assist the staff in itsobservation of licensee performance during routine activities. (B)All attributes of the evaluation criteria are not necessarily applicableto each licensee during each SALP period. For example, performancewithin a functional area may be insufficient to consider all attributes inthe assessment. However, the criteria should be considered in theevaluation of each functional area to the extent appropriate. (C)All available information should be analyzed by the SALP Board andthe regional administrator. The significance of the information,whether positive or negative, should be weighed. If information isscarce or nonexistent, a decision regarding the performance categoryas 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 FunctionalAreas," provide a format that may be useful to the SALP Board inassessing and recording licensee performance. (E)Approved: (Draft 08/10/92)13 Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IL-,Part IIIImplementation of the SALPAssessment 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 duedate for SALP Board input, and scheduled dates for the SALPBoard meeting, the licensee management meeting, and issuance ofinitial and final SALP reports for all facilities within the regionscheduled for a SALP during the fiscal year. The regions shalldistribute this memorandum to the Office of Nuclear ReactorRegulation (NRR), including the NRR SALP coordinator, theOffice of Nuclear Material Safety and Safeguards (NMSS), theOffice for Analysis and Evaluation of Operational Data (AEOD),the Office of Nuclear Regulatory Research (RES), and theExecutive Director for Operations (EDO) by the end of thepreceding fiscal year. The regions shall provide any changes toSALP schedules to these offices. The applicable SALP data inSINET should be updated as appropriate. SALP Board membersshould be notified promptly of any scheduling problems tofacilitate coordination of alternative meeting dates. (a)* Prepare a working copy of the SALP report. (b)-Integrate SALP report inputs. NRR shall provide written inputfor 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)144Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IIIAssessment by the SALP Board (A) (continued)Preparation for the SALP Board Meeting (1) (continued)-Issue the working copy of the SALP report to SAL! Boardparticipants before the SALP Board meeting. Note that thisversion of the report should not contain recommended licenseeperformance ratings. (iv)SA1!P Board Meeting (2)The SALP Board meeting will be conducted in accordance with theregional SALP implementation procedures. (a)The composition of the SALP Board is multidisciplinary in nature andis intended to result in an integrated assessment of licenseeperformance. Specification of the board's voting members is notmeant in any way to limit presentations before the board by other NRCstaff members when such presentations are appropriate. Rather, thestaff members closely associated with a functional area should beasked to discuss their views with the SALP Board. (b)Proper preparation for the SALP Board meeting is essential for votingmembers since they are expected to participate in board discussions ofeach functional area in order to contribute effectively to theassessment of the licensee's performance and the identification ofcommon themes and symptoms of that performance. All board votingmembers should (1) have visited the site during the assessment periodand reviewed plant performance and (2) be familiar with inspectionreport findings that were issued during the assessment period. Theregional administrator may exempt specific board members on acase-by-case basis from these requirements. To effectively support thegoals of the "Overview" section of the report, it is important that theboard voting membership remain constant during the evaluationprocess. As a result, SAL!P Board deliberations should be orientedtoward reaching a consensus view, when possible. (c)The SALP Board will be composed of the following members, witheach member having a vote: (d)One representative from each of the region's projects andtechnical divisions. Each divisional representative will be a divisiondirector, a deputy division director, a branch chief, or a sectionchief. (i)Approved: (Draft 08/10/92)15 Handbook 8.6 Part IIIAssessment 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 orsubstitute voting member, normally an SES-level manager, for anyspecific board. For example, an out-of-region SES-level manager or astartup reviewteam leader who has conducted an indepth review of thefacility may be appropriate. Use of board-specific voting members isexpected to be infrequent. Because of the combination of reactorprojects and reactor safety in Region V, the Regional Administratorfor Region V may appoint two representatives from the Division ofReactor Projects and Safety to ensure both the reactor projects andreactor safety perspectives are represented on each board. (e)The SALP Board Chairperson will be a regional SES-level managerand will be the divisional representative, but will not serve in additionto the divisional representative. When multiple NRR projectmanagers are assigned to different units at the same site, the projectmanagers shall cast one collective vote. A board quorum will consist ofa minimum of five persons. Generally, there should be no more thanseven voting members on the board. (f)During the SAL? Board meeting-(g)* The SALP Board members shall review and discuss the SALPreport. They shall ensure that each functional area sectionconcisely conveys the board's views, with selected examples toillustrate key findings. They shall ensure that a conclusion has beenreached regarding licensee performance within each functionalarea. They shall ensure that the discussion of performance withineach functional area identifies common themes or symptoms ofthat performance, if known. (i)16 Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Part IIIAssessment by the SALP Board (A) (continued)SALP Board Meeting (2) (continued)* The SALP Board members shall evaluate licensee performance ineach functional area after considering the evaluation criteria withtheir associated attributes listed in Exhibit 2. Exhibits 3 and 4 maybe used by the SALP Board members to assist them in assigning acategory rating for each functional area. The functional areacategory ratings will be determined by a majority vote of theboard's voting members. (ii)* The SALP Board members should recommend changes to theNRC inspection program for implementation.. at the specificfacility, as appropriate. (iii)* The SALP Board members shall identify weaknesses and/orrecommend areas for the licensee's consideration so thatimprovement in performance can be addressed. (iv)* The SALP Board Chairperson shall ensure that the licensee'soverall performance is discussed and assessed, with an emphasis onidentified strengths and weaknesses. (v)Following the SALP Board meeting, the SALP Board Chairpersonshall provide a SALP Board report with its recommended ratings andoverview to the regional administrator. The regional administratormay make substantive changes to the report before it is issued to thelicensee. If changes are made, the regional administrator should soinform 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 thelicensee. Copies of the report should also be provided to the offices ofthe EDO; the Director, NRR; the Director, Office of Enforcement; theCommissioners; and the NRR Division of licensee Performance andQuality Evaluation (DLPQ) SALP Program Manager. The lettertransmitting the SALP report will be distributed on a timely basis as astandard docket item to the Document Control System, the NRCPublic Document Room, the appropriate Local Public DocumentRoom, and the Institute of Nuclear Power Operations (RecordApproved: (Draft 08/10/92)17
- cB &%JA korLai .bL JHandbook 8.6 Part IlIIssuance of the Initial Report (B) (continued)Center, Institute of Nuclear Power Operations, 1100 Circle75 Parkway, Suite 1500, Atlanta, GA 30339). Each report will beassigned an inspection report number. (1)The transmittal letter for the initial SALP report should include thefollowing: (2)C* A characterization of overall safety performance consistent withthe "Overview" section of the SALP report. The SALP transmittalletter must highlight common themes of licensee performanceidentified by the SALP process. The transmittal letter should striveto characterize NRC's confidence in or concern with the licensee'sperformance and the underlying reasons therefor and should placein perspective any significant events or findings that took placeoutside the assessment period that bear on the evaluations in thereport. Specifically, the regional administrator shall highlight inthe SALP cover letter those areas of performance that havedeclined since the end of the assessment period. The regionaladministrator should ensure the transmittal letter is consistent withthe results of any other current events and processes related to theplant's performance, such as results of recent Senior ManagementMeetings and major team inspections, to ensure that conflictingmessages are not inadvertently transmitted to the licensee. (a)* Areas or issues that warrant discussion during the neeting with thelicensee. (b)* A request for the licensee's written comments on and amplificationof, as appropriate, the SALP report within 30 days after themeeting with the licensee. For all functional areas rated asCategory 3, the transmittal letter must require a response from thelicensee that provides planned corrective actions to improveperformance. (c)Meeting With the Licensee (c)General (1)A public meeting with the licensee's management to discuss theassessment will be held following issuance of the initial SALP report.The meeting will be conducted on site or in the vicinity of the site, if18 Approved: (Draft 08/10/92)
Systematic -' ssessment of LicenseePerformance (SALP)Handbook 8.6 Part IIIMeeting With the Licensee (C) (continued)General (, (continued)feasible, to foster accessibility and a more widespread understandingof the NRC's views.Meeting Preparation (2)The region shall notify those on distribution for the SALP report of themeeting with the licensee. (See Section (B) of Part III of thishandbook.) (a)The region shall notify the media and State and local governmentofficials of the issuance of the initial SALP report and of the meetingwith the licensee once the report has been released. Generally, at leastI week's notice should be provided before the meeting. (b)The licensee should be encouraged to have the following managementrepresentatives participate in the meeting: (c)* The senior corporate nuclear officer/manager (i)* Management officials responsible for the major functionalareas (ii)* The site manager (iii)Licensee Meeting (3)The meeting should be conducted within 90 days of the end of theassessment period. (a)The regional administrator will determine the NRC participants forthe licensee meeting. NRC participants for this meeting typicallyinclude the following: (b)* The regional administrator or the deputy administrator, especiallyif licensee performance has been rated as Category 3, orCategory 2 with a declining trend. (i)* The SALP Board Chairperson or other SES voting member of theboard. (ii)Approved: (Draft 08/10/92)19 Systematic Assessmer* of LicenseePerformance (SALP) --'Handbook 8.6 Part IIIMeeting With the Licensee (C) (continued)Licensee Meeting (3) (continued)* Responsible regional division directors, branch chiefs, or sectionchiefs, as appropriate. (iii)* The NRR project manager, project director, and/or designatedNRR SES-level manager. (iv)* 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 SALPBoard Chairperson will chair the meeting. These meetings areintended to provide a forum for a candid discussion of issues relating tothe licensee's performance. Those aspects of the licensee's operationthat need improvement will be identified, as well as the positiveaspects of the licensee's performance. The licensee also will be giventhe opportunity to provide comments on the report in writing within30 days after the meeting. Only written comments from the licenseemust be subsequently addressed by the regional administrator. (c)SALP management meetings with the licensee should be publicmeetings, unless portions of the meetings involve discussion of mattersthat are required to be withheld from the public domain pursuant toSection 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 betreated as observers. Adequate notification of the SALP meetingshould be accomplished by the timely distribution to the PublicDocument Room of the letter scheduling the meeting with thelicensee, with copies to the parties on the service list for theappropriate docket. (d)Format and Content of the SALP Report (D)General (1)The SALP report is considered a final report once the regionaladministrator has signed the transmittal letter to the licensee followingthe meeting with the licensee and after consideration of the licensee'swritten response, if any.20 Approved: (Draft 08/10/92)
Systematic msessment of LicenseePerformance (SALP)Handbook 8.6 Part IIIFormat and Content of the SALP Report (D) (continued)Report Format and Content (2)The staff shall prepare the SALP report in general conformance withthe guidelines of Exhibit 5 of this handbook.Final SALP Report (E)General (1)The regional administrator shall issue the final SALP report within 30days of receipt of the licensee's written comments or plannedcorrective actions. This report will receive the same distribution as theinitial 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 meetingwith the licensee. (i)* A summary of the meeting held with the licensee concerning theinitial SALP report. (ii)* A copy of the written comments received from the licensee. (iii)* NRC's conclusion regarding the acceptability of the licensee'splanned corrective actions, if corrective actions are required. (iv)* The conclusions of the regional administrator based onconsideration of the licensee's comments and planned correctiveactions. (v)If the licensee's response does not result in any change to the initialreport, or if the licensee chooses not to respond, the final SALP reporttransmittal may consist of the following: (b)* A summary of the meeting held with the licensee concerning theinitial SALP report. (i)* A copy of the licensee's written response, if any. (ii)Approved: (Draft 08/10/92)21 Systemafic Assessment of LicenseePerformance (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 ofthe initial SALP report and a statement that the initial report isconsidered to be the final SALP report. (iii)Changing the Initial SALP Report (3)Any changes to the initial SALP report after the meeting with thelicensee will require the following actions:* Generate a cover letter signed by the regional administrator thatauthorizes the change, the basis for the change, and its impact onthe SALP results. (a)* Attach a "SALP Board Report Revision Sheet" (Exhibit 6) as aseparate enclosure to the regional administrator's cover letterdenoting the change and the basis for the change. (b)* Add the revised page (Exhibit 7, "Sample Revised Page") to thereport, leaving the original page (Exhibit 8, "Sample OriginalPage") 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 onExhibit 8 and reference the revision sheet. (d)* Reissue the final SALP report in its entirety with corrections notedabove. (e)22 Approved: (Draft 08/10/92)
Systematic -'ssessment of Licensee-Performance (SALP)Handbook 8.6 ExhibitsExhibit 1SALP Evaluation ProcessSALP EVALUATION PROCESSSCHEDULAR GOALSEnd of AssessmentPeriod ISALP BoardPreparationSALP BoardMeetingI Initial SALPReport Issuance IMeetingI With the LicenseeLicenseeResponseFinal SALPReport IssuanceY .Within90 daysWithin30 daysWithin30 daysApproved: (Draft 08/10/92)23
'!,~.I1. Management Involvement and Control in Assuring SafetyCategory 1 Category 2 Category 3a. Prior planning results in a. Prior planning results in a. Prior planning, although ac-safe plant operations and safe plant operations and ceptable, is not.effective asexcellent coordination of good coordination of plant evidenced by, for example,plant activities; communi- activities; communication unnecessary down time ofcation between depart- between departments is safety-related equipment;ments is excellent. effective, with some minor safe plant operations are notexceptions. always a priority; communi-cations between depart-ments is limited and/or noteffective.b. Policies and procedures b. Policies and procedures b. Policies and procedures arecombine to provide excel- combine to provide good acceptable but are the rootlent control of plant activi- control of plant activities. cause of repetitive orsignifi-ties and reflect safe nuclear cant plant problems.work ethics.c. Decisionmaking demon- c. Decisionmaking demon- c. Decisionmaking demon-strates excellent under- strates good understanding strates acceptable under-standing of plant design and of plant design and safe standing of plant design andsafe plant operations. plant operations. safe plant operations.d. Management involvement d. Management involvement d. Management involvementand direction in all activities and direction in most activi- and direction in activitiesproduce excellent results. ties produce good results. produce acceptable results.N."_*nP'4D,WWOM Oe7EDCW 0Msor MPr =ox;:h_. EnI_X_.d-SOI'U0000t'
0o*0A10c.9-0-00tJit%2. Licensee's Self-Assessment CapabilityCategory 1 Category 2 Category 3a. Licensee's self-assessment a. Licensee's self-assessment a. licensee's self-assessmentconsistently identifies po- normally identifies poten- usually does not occur untiltential problems. tial problems. after a potential problembecomes apparent.b. Self-assessments involve all b. Self-assessments normallylicensee 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 potentiallems. problems.c. Line organization involve- c. Line organization involve- c. Line organization involve-ment, safety review corm- ment, safety review commit- ment, safety review commit-mittees (independent safety tees, and feedback from tees, and feedback fromengineering group [ISEG], QA/QC activities are nor- QA/QC activities are slowonsite and offsite review mally used to provide self- to identify deficient condi-committees, etc.), and assessments and improve tions, as evidenced by prob-feedback from quality work activities, although lem areas that areassurance/quality control some examples are evident self-disclosing before active(QA/QC) activities are in which this was not the involvement of self-effectively used to provide case. assessments.critical self-assessment andimprove 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-potential problems. tential problems, although nificant issue or numerous.some examples exists in minor issues developingwhich minor issues were from previously identifiedmisclassified and therefore industry problems.unresolved.5f_-k4:0_i.:3AD0I...-.-3.toM-_
oic.33. Approach to the Resolution of Safety Issues and the Effectiveness of Corrective ActionCategory I Category 2 Category 3a. Evaluations of technical a. Evaluations of technical a. A clear understanding of theissues display a clear' issues usually show a clear safety implications is notunderstanding of the safety understanding of the safety demonstrated on a signifi-implications of the issue. implications of the issue. cant issue, or a number ofless significant examplesexist in which evaluations oftechnical issues displayed aweak understanding of thesafety implications.b. Conservatism is routinely b. Conservatism is usually b. Minimum requirements areexhibited when the poten- exhibited. met.tial for safety significanceexists.c. Approaches to problem c. Approaches to problem c. Approaches to problemresolution and corrective resolution and corrective resolution and corrective ac-action show a pattern of be- action are viable and gener- tion are often viable, buting technically sound, corm- ally sound and thorough. lacking in thoroughness orprehensive, and thorough in depth.almost all cases.d. Corrective action is effec- d. Corrective action is usually d. Corrective action is oftentive, as indrcated by lack of effective, although there not effective, as evidencedrepetition of events. may be an occasional repe- by repetition of a significanttition of a minor problem. problem or frequent repeti-tion of minor problems.Z10 ('0. ~w r,er -CO p ,X, e ;00 MEAr--SU-..CT-t00.CL~1-10I-W0CD0I'J(
3. Approach to the Resolution of Safety Issues and the Effectiveness or Corrective Action (continued)Category 1 Category 2 Category 3e. Resolutions are timely in e. Resolutions are generally e. Resolutions are sometimesalmost all cases. timely. delayed on significant issuesor frequently delayed onminor issues.f. Excellent corrective action f. Good corrective action is f. Corrective actions are ac-is apparent through elimi- apparent through reduction ceptable; however, causalnation of causal factors for of most causal factors of factors reappear in plant is-plant issues. plant issues. sues that indicate actionshave not been thorough.g. Root cause analyses are g. Root cause analyses are g. Root cause analyses oftenthoroughforsignificantand good for significant issues. do not probe far enough,minor issues and address all Some minor issues that may resulting in incompleterelevant contributors to the not receive as thorough a identification of root causesissues. root cause analysis result in and recurrence of plantrecurrence of minor issues. issues.5Xas-0~to= OV cPa6 M:rr S =cay to 0Ah =s2 "'uyl I Ll coo'f4. Operational and Construction EventsCategory 1 Category 2 Category 3a. Few significant operational a. Occasional operational or a. Frequent operational oror construction events are construction events occur construction events occurattributable to causes under that are attributable to that are attributable tothe licensee's control. causes under the licensee's causes under the licensee'scontrol. control.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, orported. although some deficiencies reporting is late.are identified in the licen-see's process.0 "Moa1* Elp'_. e'I.(Xti<:r~T1I-.0CDAnT100CLr-a0t'I 5. Stnlling and Application or ResourcesCategory 1 Category 2 Category 3a. Positions are identified and a. Key positions are identified a. Positions are poorly identi-authorities and responsi- and responsibilities de- fied or authorities andbilities are well defined. fined. responsibilities are illdefined.b. Key vacant positions are b. Key vacant positions are b. Key positions are left vacantfilled on a priority basis. usually filled in a reason- for extended periods.able time.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 orlog and overtime. sional backlogs or use of minimal, as evidenced byovertime. large backlogs or use ofovertime.d. Staffing has sufficient depth d. Staffing has sufficient depth d. Staffing lacks depth.and minimizes the impact of in most cases.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-timely manner. tiveness of programmaticand/or corrective action._t%)00._.M"It o3ta".M-Cr "I sA6 aV) _ M a!0U3CDi10Q.00o(t00CD6. Elfectiveness orTraining and QualilicationCategory ICateporv 22 -., -a. The training and qualifica-tion programs make a largepositive contribution com-mensurate with proceduresand staffing to the under-standing and accomplish-ment of work.b. The training program iswell defined and imple-mented with dedicated re-sources.c. Inadequate training is not aprimary root cause of majoror minor problems.d. Procedures and policies arefollowed. Some isolated de-.partures from, proceduresmay exist.a. The training and qualifica-tion programs contribute tothe overall understanding ofwork, as evidenced by fewpersonnel errors.b. A defined program is imple-mented for most of the staff.c. Inadequate training is not aprimary root cause of majorproblems.d. Procedures and policies arerarely violated.Category 3a. The training and qualifica-* tion programs do not con-tribute to the understandingof work, as evidenced bypersonnel errors or numer-ous procedural violationsthat contribute to significantissues or repeated minorissues.b. The training program ispoorly defined or ineffec-tively implemented for a sig-nificant portion of the staff.c. Inadequate training is a pri-mary root cause for signifi-cant or numerous minorproblems.d. Procedures and policies areoccasionally violated, indi-cating continuing or fre-quent problems.O MS1-V=11-wet7dbill*V-9.W::Jr--O-51C:00.%_-1 Ii~100CT'0o*1-.-.ol00-SWI..,7. Enforcement HistoryCategory 1 Category 2 Category 3a. There are no major safety- a. Major violations are rare. a. Multiple major violationssignificant violations. Minor program breakdown occur or programmaticmay be indicated. breakdown is indicated.b. Minor violations are not b. Occasional multiple minor b. Minor violations are repeti-repetitive. violations. tive or programmaticbreakdown is indicated.P_.WCr"weC::on.-I_.,$ Sco 6 F0 _7 S
- L ;& I A1141MV kalt: iLr)Handbook 8.6 ExhibitsIExhibit 3Evaluation Matrix for Operating Phase Functional Areas-IIIa B;I2 .XV -S w.CCj =DI,C.Ur7EceUCaUV)WUt.z04UW'3 C= d.0Pt wU 1"" -4C. ga.-"a.IIUEQUla._..CXoVCC.ot~a_cosrZC*UzL.I.-C5coU._._3UoUb_ICEu3.C11w.OperationsMaintenanceEngineeringi._Plant SupportOther---i- 111111132 Approved: (Draft 08/10/92)
-4-Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 ExhibitsExhibit 4Evaluation Matrix for Construction Phase Functional Areas-. --1 1 7Vaes4 ,,r= wI=E .EP-5 -_C =as-"v*a.aeC)EuU,C.-LiU,wU,a4Li3 CC',w'S.,.& oa:-a.-3 w,£: .-U t!qw C-SC CEaC)ElaC:"aCI-C),0V5-CC.CaV.OaaaC:aCaVCaa4-CaC,UCiC?a4 ,ELi,..94-+ 4 1 4- 4. 4 -Soils and Foundations_ 41Containment, Major Structures,and Major Steel SupportsPiping Systems and Supports IMechanical ComponentsAuxiliary Systems IElectrical Equipment and CablesInstrumentationEngineering/Technical SupportOther I I I IAnnrn-.?i- 1lr,' fnQJ1 n/o1 \
Systematic Assessmer' of LicenseePerformance (SALP)'-"Handbook 8.6 ExhibitsExhibit 5[Initial or Final] SALP ReportU.S. Nuclear Regulatory CommissionRegion [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 ExhibitsExhibit 5 (continued)INTRODUCTIONThe Systematic Assessment of Licensee Performance (SALP) Program is anintegrated NRC staff effort to collect available observations and data on a periodicbasis and to evaluate licensee performance on the basis of this information. Theprogram is supplemental to normal regulatory processes used to ensure compliancewith NRC rules and regulations. It is intended to be sufficiently diagnostic to provide arational basis for allocating NRC resources and to provide meaningful feedback to thelicensee's management regarding the NRC's assessment of its facility's performance ineach functional area.An NRC SALP Board, composed of the staff members listed below, met on [date], toreview the observations and data on performance, and to assess licensee performancein accordance with NRC Manual Directive 8.6, "Systematic Assessment of LicenseePerformance (SALP)" (formerly MC 0516).This report is the NRC's assessment of the licensee's safety performance at [name offacility] 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 RESULTSA. Overview[The ratings assigned to the individual functional area are only one aspect resultingfrom the SALP process. The SALP Board is expected to assess each functional area insuch a manner that the SALT Board discussion focuses on understanding the reasonsfor the observed performance. The attributes and assessment criteria provided inHandbook 8.6, Part II, "Evaluation Criteria," should be used to develop a uniform andconsistent approach. After assessing all of the functional areas, the SALP Board isexpected to discuss commonalities, if any, among the functional areas. This process ofreviewing the summary results from the standpoint of identifying common underlyingreasons for the licensee's performance is the basis for the overview. The overviewshould also note functional areas in which ratings have changed since the previousperiod and discuss the reasons for the changes. The overview should not be a summarystatement of the individual functional areas; rather, the overview is intended to be anexecutive summary with a synopsis of the underlying reasons in the view of NRCmanagers for both good and poor licensee performance as well as for changes inApproved: (Draft 08/10/92)35 Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 Exhibits-' _Exhibit 5 (continued)II. SUMMARY OF RESULTS (continued)performance. With regard to poor performance, the overview developed should besomewhat specific so that the licensee may be fully aware of the areas in whichincreased utility management attention is required. The overview should also includeany recommendations assigned to functional areas. In addition, a table ofperformance category ratings should be provided, as indicated below.To emphasize topics for consideration beyond the specified functional areas, theOffice of Nuclear Reactor Regulation (NRR) may identify selected topics for inclusionas part of the overview. These selected topics will be addressed by all SALP Boards fora defined period, and the summary results will be included as a part of the overview.][Functional area] [Rating last period] [Rating this period] [Trend, if any, and providethe trend definition as a footnote]B. Other Areas of Interest[Provide an overview of licensee performance in each topic area. These topic areas aredetermined by the Director, NRR, and/or the regional administrator.]III. PERFORMANCE ANALYSISA. [State the functional area being discussed] [Briefly state the inspections thatwvere performed in this area]1. Analysis[This analysis should concentrate on the licensee's performance with respect to theevaluation criteria and attributes. This section should not necessarily reiterate ortabulate the information and data that contribute to the analysis; rather, it should be asummary of the supporting rationale. The analysis should be concise yet should fullycommunicate the NRC's assessment of licensee performance. The length of eachfunctional area analysis should reflect the applicable NRC resources expended and thelicensee activities during the assessment period. Any appropriate information and datashould be provided in Section IV of this report. Licensee performance should bediscussed in light of the evaluation criteria and associated attributes both to ensurecompleteness and to compare licensee performance across functional areas. Theanalysis is intended to be sufficiently diagnostic to provide a rationale for allocatingNRC resources and to provide meaningful feedback to the licensee's management.]36 Approved: (Draft 08/10/92)I Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 ExhibitsExhibit 5 (continued)III. PERFORMANCE ANALYSIS (continued) -2. Performance Rating[Provide the performance rating (Category 1, 2, or 3) for each functional areaconsidered. If appropriate, include a trend assessment (improving or declining).]3. Recommendations[Include any general or specific NRC recommendations pertaining to either thelicensee'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, theregional office may do so at its discretion on the basis of appropriate NRCmanagement directives.]IV. SUPPORTING DATA AND SUMMARIESA. Major Licensee Activities[Provide a factual outline of major licensee activities, such as major outages, powerlimitations, important license amendments, and significant modifications.]B. Direct Inspection and Review Activities[Provide a factual summary of major direct inspection and review activities performedby resident inspectors, region-based staff, and headquarters staff in each functionalarea. This is not intended to be a summary of each inspection or review performed butrather of those that had a significant effect on the results discussed in Section III of thisreport.]C. Other[Discuss any other issues, at the discretion of the SALP Board.]Approved: (Draft 08/10/92)37 Systematic Assessmeijf LicenseePerformance (SALP)Handbook 8.6 ExhibitsaExhibit 6Sample SALP Board Report Revision SheetPAGE5LINE2NOW READSTwo of the threeplant trips this as-sessment periodresulted from in-correct operationof the feedwaterregulation bypassvalves.SHOULD READOne of the three planttrips this assessmentperiod resulted fromincorrect operation ofthe feedwater regula-tion bypass valves.Another resultedfrom insufficient rootcause determinationof the failure of a sole-noid valve in the samesystem.Basis: The SALP incorrectly stated the cause of two reactor trips wasincorrect operation of the feedwater regulation bypass valves. TheSALP has been changed to reflect the actual cause of the two planttrips.38 Approved: (Draft 08/10/92)
Systematic Assessment of LicenseePerformance (SALP)Handbook 8.6 ExhibitsExhibit 7Sample Revised PageThe licensee's corrective action has not been effective in all cases, as indicated byrepetition of valve operation problems noted in the previous SALP. One of thethree plant trips this assessment period resulted from incorrect operation of thefeedwater regulation bypass valves. Another resulted from insufficient root causedetermination of the failure of a solenoid valve in the same system. The previousSALP report noted two cases of incorrect operation of the same valves.Plant operators exhibited excellent control of transient plant conditions, reflectinghigh-quality training. Good response by control room operators was notedfollowing an inadvertent trip of the turbine electrohydraulic control system pumps,inadvertent tripping of a circulating water pump, and failure of the cold-legtemperature instrument. These responses averted two plant trips and unnecessaryplant transients. During a surveillance test on a pressurizer pressure instrument,manual control of plant pressure was necessary. Rehearsal of this operation on theplant simulator and pre-evolution planning for potential transients during the testenable operators to expeditiously respond to a spurious opening of the spray valve.Operator attention to detail and adherence to procedures in performance ofrepetitive or routine activities exhibited problems. Weaknesses were noted in thethoroughness 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. Multiplecontrol rod misalignment events occurred during the unit startup, reflectinginattention by the operators. On several occasions, ineffective communicationswithin the control room, or between the control room operators and personnel inthe plant, contributed to events. The consistency of shift turnover, walkdowninspections, and equipment status tracking improved during the later portion of theperiod by formalizing the turnover process via an operations department procedureand by the use of a plant status list.The licensed operator requalification program was evaluated this assessment periodwith excellent results. NRC examiners noted excellent control of transientconditions by the senior reactor operators. One minor programmatic concern wasidentified and promptly corrected. The licensee provides sufficient time andexcellent training facilities to effectively train and requalify licensed andnon-licensed operators. Staffing levels were excellent, as evidenced by fully staffedsix-crew rotation and the availability of additional licensed operators for plannedheavy workload periods. Overtime was well controlled and not excessive.5AI 39Approved: (Draft 08/10/92)T39 systematic Assessment of LicenseePerformance (SALP) -Handbook 8.6 Exhibit_IExhibit 8Sample Original PageVc'nsee's corrective action has not been effective in all cases, as indicated byof valve operation problems noted in the previous SALP. Two of thetrips 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 condihigh Good response by control room operators vfollow. \ trip of the turbine electrohydraulic controinadvertu irculating water pump, and failure of thetemperata .else responses averted two plant trips aplant trans'e, eillance test on a pressurizer pressu:manual controA was necessary. Rehearsal of thisplant simulator a. T lanning for potential transientsenable operators tL \ ond to a spurious opening ofOperator attention to v p -ice to procedures in perfoirepetitive or routine acti. nblems. Weaknesses werthoroughness of periodic p. pections by operators.on one occasion a valve misa. v service water operaidentifiable from the main cont. % 'ndetected for fourAdditional problems with effectiv C, 's tracking werecontrol rod misalignment events oc% + unit startup, rainattention by the operators. On sevt. ffective cornwithin the control room, or between tht. ,rators anthe plant, contributed to events. The con:. mover,inspections, and equipment status tracking i. .'he lateperiod by formalizing the turnover process via narland by the use of a plant status list.The licensed operator requalification program was Kwith excellent results. NRC examiners noted excellen.conditions by the senior reactor operators. One minor Zidentified and promptly corrected. The licensee providesX.excellent training facilities to effectively train and requalify J.non-licensed operators. Staffing levels were excellent, as evio,six-crew rotation and the availability of additional licensed operaheavy workload periods. Overtime was well controlled and not ex.tions, reflectingvas noted1 system pumps,cold-legand unnecessaryre instrument,operation on theduring the test* the spray valve.-mance of*e noted in theFor example,ability,operating shifts.noted. Multipleeflectingmunicationsd personnel inwalkdowner portion of thetment procedure-ssment period'ent-cern was\e\ fed540Approved: (Draft 08/10/92)
f -- it ;<V Am l:--2 -September 4, 1992This generic letter contains no information collection requirements andtherefore is not subject to the requirements of the Paperwork Reduction Act of1980 (44 U.S.C. 3501 et seq.).-Please contact Cornelius Holden (301-504-1037) if you have any questions aboutthis matter. No specific licensee actions are required.
Sincerely,Original signed:James G. PartlowAssociate Director for ProjectsOffice of Nuclear Reactor Regulation
Enclosure:
As statedDISTRIBUTION:Central FilesLPEB R.F.CHoldenAMendiolaGGZechCOThomasJWRoeGMarcusWTRussellJGPartlowNRC PDRt See previous concurrenceOFC LPEB:DLPQ SC:LPEB:DLPQ TECH EDITOR BC:LPEB:DLPQ DD:DLPQ:NRRNAME CHolden:jp AMendiola JMain GGZech COThomasDATE 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 oaAfinqAME JWRoe GMarcus WTRussell JGPartlowJATE I8/31/92*8/31/92*Ioq/0l_ .-I , _,OFFICIAL RECORD COPYDocument Name: SALPWRKS.GEN12* 9/4 /92