ML20202G090
| ML20202G090 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1999 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Dyer J, Miller H, Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9902040294 | |
| Download: ML20202G090 (11) | |
Text
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. ) - January 29, 1999 MEMORANDUM TO: Hubert J. Millcr, Regional Administrctor, RI Luis A. Reyes, Regional Administrator, Rll
, James E. Dyer, Regional Administrator, Rlli Ellis W. Merschoff, Regional Administrator, RIV FROM: Samuel J. Collins, Director (original signed by:)
Office of Nuclear Reactor Regulation l l
SUBJECT:
CONSOLIDATED GUIDANCE FOR PLANT PERFORMANCE I REVIEWS NRR provided guidance for Plant Performance Reviews (PPRs) to the regional offices in memorandums dated September 24,1998 and December 15,1998, and in a video teleconference on January 15,1999. This was provided to implement the Commission's guidance for suspending the Systematic Assessment of Licensee Performance (SALP) -
program that was provided in the staff requirements memorandum dated September 15,1998, for COMSECY-98-024, " Response to issues Raised Within the Senate Authorization Context and Ju!y 17,1998 Stakeholder Meeting."
Attachment 1 consolidates the above guidance for PPRs. It will be incorporated into inspection Manual Chapter 0304, Plant Performance Reviews," as appropriate following completion of the ongoing accelerated initiatives in inspection, assessment and enforcement that are discussed in COMSECY-98-024 and its updates.
Attachment 2 provides a sample PPR cover letter to be sent to licensees following the early 1999 SMM screening meetings. The letter is based on using existing information in the narratives that is developed for PPR and SMM screening meetings. Attachment 3 provides an example of a completed PPR letter.
Attachments: As stated cc: R. Blough, RI D.Chawaga,RI L. Plisco, Rll R. Lanksbury, Rlli G. Grant, Rill . L. Yandell, RIV K. Brochman, RIV B. Boger, NRR J. Lieberman, OE G. Tracy, EDO M. Tschiltz, EDO V. Dricks, OPA I W. Beecher, OPA F. Miraglia, EDO OSP CONTACT: Tom Boyce, NRR/PIPB 301-415-1130 1 Djstribution:
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- See previous concurrence.
To receive a copy of this document indicate in the box: "C" = Cooy withoutenqlosures "E" = Copy wjib enclosures "N" = No copy /
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OFFICE PlPB: DISP E PIPB: DISP E PIPB:DtSE FE DISP:NRR E D(NRMM' NAME THBoyce
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CONSOLIDATED GUIDANCE ON PLANT PERFORMANCE REVIEWS (PPRs) 1 l 1. Context of Licensee Performance. The first sentence in the paragraph for overall assessment now provides the context for the rest of the NRC's assessment. The purpose I of this sentence is to help the public put into context the relative significance of the assessment or issues in any functional area, and to help regional branch chiefs address similar questions if asked during a public meeting. The last sentence of each paragraph should state any changes in the NRC's inspection schedule. The sentences in between I shou!d make it clear whether the changes in the NRC's inspection schedule are driven by performance or events (regional initiative or reactive inspection), or whether the changes result from the normal implementation of the NRC's inspection program (routine inspection not scheduled during previous assessment cycle). Assessment information on performance should be related to both past and future inspections that are performed above the core program, including reactive and regional initiative inspections. Inspections scheduled to meet normal program requirements should be characterized in that manner.
- 2. Public Meetings. Per the SRM of September 15,1998, suspending the SALP program, meetings discussing licensee performance should be held every 2 years for most plants.
This means that about 50% of plants will have public meetings each year, although plants with negative performance trends should have public meetings more frequently. Various types of public meetings may be sufficient to provide the NRC's assessment of licensee performance. For example, for those plants pending restart after an extended shutdown, public meetings that are held may be sufficient if they discuss a full range of licensee performance, as determined by the regional administrator.
Regional branch chiefs should conduct the meetings for most plants, but regional management should be involved as appropriate depending on performance trends or whether significant public interest is expressed. For example, for the poorest performing plants (e.g., Watch List plants or trending letter plants), regional administrators should conduct public meetings with licensees about every 12 rronths. For plants that are not poor performers, but warrant increased management focuses, the appropriate regional division director should conduct public meetings approximately every 12-18 months. For most plants, the appropriate regional branch chief should conduct public meetings every 24 months. Meetings should focus oq published PPR results.
Public meetings should be held following the February 1999 SMM Screening Meetings.
Plants with significant performance issues should be held first, then those plams that could exceed 2 years since the last public meeting that discussed performance should be held.
Meetings required for SMM plants should be scheduled shortly after the SMM. All reauired public meetings should be held within 6 months of the February 1999 PPR. Regions may hold public meetings after mid-cycle PPRs if necessary for workload distribution, provided that t5e interval between public meetings does not exceed 27 months. In this case, regions may want to publish additional assessment information in the letter providing the results of the mid-cycle PPR. Meetings should be tracked and recorded in RPS/SALP.
Each region should provide its schedule for public meetings to NRR/PIPB shortly after the SMM screening meetings. If the required meetings cannot be held as discussed above, f inform the PPR Program Manager (Tom Boyce).
l Attachment 1 l
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- 3. Levelof Detailin fullPPR Letters. The SRM suspending the SALP program directed that PPR letters ghgil include performance trend information. This means that additional assessment information must be provided beyond that previously contained in PPR letters.
The PPR letter will be the primary means to communicate assessment information until a new assessment process is implemented; therefore, the level of detail must be sufficient for all NRC stakeholders, including state and local officials and members of the public, to understand licensee performance. In general, the level of detail should be based on the safety significance and breadth of issues, with emphasis on significant programmatic or technical issues, to ensure that management attention is focused on significant issues. For those plants that warrant increased regulatory and plant management attention, and plants that will be discussed at the SMM, the letter should provide a corresponding level of detail of discussion. For planning purposes, the new assessment process is also anticipated to communicate the information used to assess 1.icensee performance.
Information for the PPR letters should be derived from the PPR packages so that it reflects the information considered during the PPR. The assessment information for many plants does not need to be lengthy. But, the information should contain an overall assessment and address each functional area. The attached sample letter is intended to be typical for most plants. It consists of about 2 % pages, including about 1 page of boilerplate. The discussion should be supported by issues that are documented in the attached Plant issues Matrix (PIM). Significant issues from the PIM should be included in the discussion if appropriate to clearly illustrate performance assessment. The discussion should include any known significant actions taken by the licensee to address performance issues, such as licensee self-assessments and corrective actions, provided this information is docketed and publically available.
- 4. Scope of mid-cycle PPRs. A mid-cycle PPR should be held approximately 6 months after the February 1999 PPRs. The primary purpose of the mid-cycle PPR is to adjust NRC inspection resources, if appropriate, based on licensee performance. Similar to current PPR letters, the mid-cycle PPR letters should emphasize changes or trends in licensee performance since the last assessment, and the level of detail of assessment information only neeos to be sufficient to make clear the reasons for any changes in the inspection schedule. If a public meeting follows the mid-cycle PPR, then the regions may want to publish additional PPR assessment information to support the public meeting. The regions need only prepare a mid-cycle PPR package sufficient to support inspection p;anning at the PPR, but need not prepare a formal PPR package per IMC 0304, " Plant Performance Reviews," unless desired.
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or since October 1,1997 (the data PIMs were first made public), whichever is later. For the February 1999 PPRs, this means that the longest attached PIM should be about 16 months. Future PIMs need only be since the last " full" PPR letter, so that the maximum length of a PIM would be 12 months. The intent is that the length of PIMs be consistent with the assessment period of the PPR letters, so that licensees and other stakeholders will have all necessary information in one package.
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- 8. Assessment Period Covered by PPRs. All PPRs should examine any assessments that have been conducted since the last comprehensive report of licensee performance (e.g.,
l SALP, " full" PPRs, IMC 0350 meetings) for long term trends, but emphasize performance during last 6 months. The attached sample PPR letter includes a sentence to this effect to ensure this is appropriately conveyed to licensees and other stakeholders.
l 7. Timing of PPR Letters. Letters providing the results of " full" PPRs should be sent to all licensees shortly after the SMM screening meetings. A draft version of the PPR letters is desired to be submitted in the submission package for the SMM screening meeting if available. Additional letters may be provided to these licensees after the SMM in accordance with SMM guidance.-
l 8. Consistency / tone of PPR /etters. PPR letters are to be sent to all licensees following the l SMM Screening Meetings. To facHitate consistency of the PPR letters, example PPR letters for good performers, SMM plants, and plants with performance issues (or drafts of l the actual letters) should be forwarded electronically to Tom Boyce (thb on email) in NRR, with info copies to the other regions. If time permits, NRR will schedule a conference call l
with the regions prior to the SMM screening meeting to discuss any observations, issues, or improvements to the letters. These draft letters are requested as soon as possible after the I PPRs in each region to support achieving consistency prior to the SMM screening meetings. If resources do not permit these example letters being generated immediately after the PPR, draft PPR letters for all plants are desired to be submitted as part of the j SMM screening package submitted to NRR if available.
- 9. SMM Coding on P/Ms. Coding of PIM entries by SMM codes is required. NRR recognizes that these codes may only be utilized in the assessment process for SMM plants. However, the new assessment process may use some form of coding PIM findings, including this l approach, and therefore regions should continue to code PIM entries. NRR will continue to l evaluate this issue.
- 10. SMM Template Discussion. Narrative in the format of the SMM template areas is not l required or desired for either the PPRs or the SMM screening meetings, except for those l plants being discussed at the SMM. The discussion in the SMM screening meeting shoul:1 be presented in the same format as the PPR packages (overall assessment, then i
assessment in each functional area).
- 11. Distribution forPPR Letters. Do NOT include the Commission. Ro include the PPR Program Manager in PIPB (Tom Boyce), the Chief, inspection Program Branch, NRR, and the Chief, Regional Operations and Program Management Section, OEDO (Glenn Trac)),
in addition to all SALP and PPR stakeholders. Regions should make every reasonable effort to ensure that state and local officials, any known interested parties, and any other organizations and individuals that may utilize SALP reports are made aware of the SALP suspension. For example, those that normally receive copies of the SALP report should be I
added to the distribution for the letters providing the PPR results to licensees.
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- 12. Role of NRR Projects in PPRs. Project Managers and Directors are required to stay informed of issues affecting their plant, and therefore will monitor and participate in PPRs as appropriate. Projects input should be focused on PIM entries related to licensing issues, especially those PIM entries originated by Projects, but supporting observations may also be provided on other issues, recognizing that only docketed information can be utilized for assessment of licensee performance. Participation will normally be via video teleconference or phone rather than physical presence. Regions should ensure that Project Managers are kept informed of the schedule for PPRs.
- 13. Phone calls to Licensees. Phone calls to discuss PPR results with licensees may be held prior to release of PPR. letters only for the purpose of ensuring that inspection schedules are appropriately coordinated with licensees. After the PPR letters are signed, phone calls with licensees should be held to communicate the PPR assrf,sment information and describe the process used to arrive at the assessment, particularly for those plants with performance issues. l I
- 14. Feedback / Lessons Leamed from early 1999 PPRs and SMM. PIPB requests feedback from each region on the early 1999 PPRs SMM screening meetings, and SMMs, particularly any feedback from licensees and other stakeholders. Please provide this as soon as possible, but no later than April 30. The results will be utilized to improve the PPRs, SMM process, and the new assessment process that is being developed.
- 15. NRR Assist to Regions for PPRs. The PPR Program Manager is available to the regions to provide program assistance in advance of the PPRs. This includes travel to each region, review of regional assessment guidance, conference calls, and answering questions that may arise. PIPB will also be sending a representative to each region's PPR for assistance and observation.
- 16. Consistency of F/Ms/lRs/PPR assessments. A good business practice is for the regions to ,
review the draft PIM entries for each IR at the same time as the IR is briefed / staffed within a region before the inspection report is issued, rather than develop the PIM after the inspection report is issued. This ensures that important assessment information is consistent in both between inspection reports and the PIM, is reviewed by region management, appropriately conveyed to licensees and characterized in the PIM, and eliminates " revisionist history." This also helps keep the PIM current and readily available for emergent needs.
- 17. Signers of PPR Letters. Regional Division of Reactor Projects branch chiefs may continue to sign PPR letters. However, the appropriate division director or regional administrator should sign PPR letters for plants where licensee performance trends warrant increased management attention.
- 18. Inspection Planning Cycles. During the period that SALP is suspended, inspections should continue to be scheduled and performed in accordance with existing SALP inspection cycles using IMC 2515 hours and frequencies. Regions should adjust the lenfjth of the inspection planning cycles (currently 12-24 months) as appropriate based on licensee performance. The periodicity of inspection cycles is currently being reviewed as part of a 1
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5 risk-informed rebaselining of the core inspection program. For planning purposes, this effort is expected to result in annualized planning for inspection in FY 2000. Agency systems referring to SALP should continue to be utilized, including the Reactor Program 4
System (RPS). For example, RPS/SALP should be used to define the start and end dates of the inspection planning cycle, but SALP scores will not be entered for SALP boards that have not been convened. Potential changes to agency systems are currently being reviewed and any required guidance will be promulgated separately.
, PPR SAMPLE LETTER l
Licensee d' aibution designate j Licensee name/ address j
SUBJECT:
PLANT PERFORMANCE REVIEW- SITE NAME On (date), the NRC staff completed a Plant Performance Review (PPR) of (plant name). The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance. The results are used by NRC management to facilitate planning and allocation of inspection resources. PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews. PPRs examine information since the last assessment of licensee performance to evaluate long term trends, but emphasize the last six months to ensure that the l assessments reflect current performance. The PPR for (plant name) involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period (include months and years). The NRC's most recent summary of licensee performance was provided in a letter of (include date of SALP letter) and was discussed in a public meeting with you on (include date of meeting).
l As discussed in the NRC's Administrative Letter 98-07 of October 2,1998, the PPR provides an assessment of licensee performance during an interim period that the NRC has suspended its Systematic Assessment of Licensee Performance (SALP) program. The NRC suspended its l SALP program to complete a review of its processes for assessing performance at nuclear power plants. At the end of the review period, the NRC will decide whether to resume the SALP program or terminate it in favor of an improved process.
During this period, (provide a br!ef summary of plant operating history).
Overall, performance at (plant name) was acceptable (or acceptable with some areas for improvement observed as discussed below). (include a plant performance overview, similar to the first paragraph (s) in Section i of current PPR and SMM screening meetings narratives. Discussion of SMM template areas is not required or desired in this letter.)
(For each functional area, include 1-2 paragraphs on performance trends. Each functional area should be concluded by a statement of any changes to the inspection effort or whether core inspection effort would be maintained. This discussion should be similar to paragraphs' il.A and ll.C of curcsnt SMM narratives, arad should include appropriate references to examples in the PlM. Consider licensee problem identification and corrective actions, if appropriate and the Information is docketed and publically available. Use plain English to the extent possible and avoid overly technicaljargon.)
Enclosure 1 contains a historicallisting of plant issues, referred to as the Plant issues Matrix (PIM), that were considered during this PPR process to arrive at an integrated view of licensee performance trends. The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and (licensee name). The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately. Rather, the NRC only documents issues that the NRC believes warrant Attachment 2
2 management attention or represent noteworthy aspects of performance. In addition, the PPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration.
This material w,n be placed in the PDR as part of the normalissuance of NRC inspection reports and other correspondence.
This letter advises you of our planned inspection effort resulting from the (plant name) PPR review. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite.
Enclosure 2 details our inspection plan for the next 6 months. (Include additional months as necessary to ensure that the inspection schedule covers the period until the next PPR letter). Also included in the plan are NRC non-inspection activities. (include this sentence only when non-inspection activities are provided in the inspection / activity plan). The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed due to their ongoing and continuous nature.
We willinform you of any changes to the inspection plan. If you have any questions, please contact (DRP Branch Chief) at (telephone number).
(Signed by), Chief Reactor Projects Branch Division of Reactor Projects Docket Nos. 50-ABC,50-XYZ License Nos. NPF-0, NPF-00
Enclosures:
- 1. Plant issues Matrix
- 2. Inspection Plan cc:
Normal cc list + any additional SALP recipients Distribution:
Normal distribution list
+ Chief, NRR/ DISP /PIPB
+ Chief, OEDO/ROPMS
+ TBoyce, NRR/ DISP /PIPB
I PPR EXAMPLE LETTER Licensee distribution designate Licensee name/ address
SUBJECT:
PLANT PERFORMANCE REVIEW-(PLANT NAME) UNITS 1 AND 2 On (date), the NRC staff completed a Plant Performance Review (PPR) of (plant name). The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance. The results are used by NRC management to facilitate planning and allocation ofinspection resources. PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews. PPRs examine information since the last assessment of licensee performance to evaluate long term trends, but emphasize the last six months to ensure that the assessments reflect current performance. The PPR for (plant name) involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period November 5,1996 to August 1,1998. The NRC's most recent summary of licensee performance was provided in a letter of December 12,1996 and was discussed in a public meeting with you on January 10,1997.
As discussed in the NRC's Administrative Letter 98-07 of October 2,1998, the PPRs provide an assessment of licensee performance during an interim period that the NRC has suspended its Systematic Assessment of Licensee Performance (SALP) program. During this interim period, the NRC will complete a review of its processes for assessing performance at nuclear power plants. At the end of the review, the NRC will decide whether to resume the SALP program or terminate it in favor of an improved process.
During this period, Unit 2 operated near or at 100 percent power. As of March 13,1998 Unit 2 had run for 169 consecutive days exceeding a previous Unit 2 record run of 143 days. Unit i entered the period at 100 percent power and shut down for refueling outage A6R02 on August
- 13. The unit was made critical on October 10 and reached 100 percent power on October 22.
The unit operated at or near 100 percent power until the reactor tripped on December 25 during troubleshooting of the main turbine hydraulic control system. Unit 1 was cor lected to the grid on January 2 and remained at or near 100 power for the remainder of the period.
Overall, performance at (plant name) was acceptable. The plant continued to make progress in enhancing station performance. This included completion of activities on Unit 2 to warrant modification of the 1996 Contirmatory Action Letter (CAL) to allow restart. Overall, operating performance for Unit 2 was very good, with no notable transients occurring. Operators generally performed well during routine operations, as well as during a controlled shutdown of Unit 1, and the heatup of Unit 2 for restart.
Although licensee performance has significantly improved over the past 3 years, the organization continued to be challenged by a very large workload which included completion of the Unit 2 steam generator replacement outage and dealing with emerging hardware issues for Unit 1 which resulted in about a one month forced outage. Also, evaluation of service water fouling problems from sea life growth, which resulted in degraded service water heat exchanger Attachment 3
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. 2 performance and contributed to the inoperability of a safety related chiller, challenged the licensee's organization. Corrective actions to determine and correct the cause of the fouling were not prompt and required NRC involvement in addition, weaknesses were noted in the licensee's corrective action process implementation. These problems were identified by the Quality Assurance organization; however, effective management of these problems was not l evident. Other challenges included implementation of the work control process implementation l and reduction of backlogs.
In the operations area, operators generally performed well during routine operations. However, some configuration controlissues occurred for both units. Although training and qualification of operations personnel was satisfactory, the results of ongoing training raised concerns regarding the effectiveness of the Requalification training program. Management and Independent Oversight of the station were effective in enhancing station performance. Management attention to address operator workarounds, control room deficiencies, and the operations procedure revision backlog was appropriate. However, weaknesses existed in the corrective action process implementation. These problems were identified by the Quality Assurance organization; however, effective management of these problems was not evident. The performance during this period does not warrant any additional inspection effort above the normal NRC inspection program, although some increased emphasis will be placed on the areas identified above.
The maintenance organization exhibited strong management and ' teamwork, but continued to be challenged by its planning and scheduling process, emergent work activities, and reduction of backlogs. In addition, maintenance planning and implementation problems continue to occur during maintenance activities. Unit 1 material condition was good, while Unit 2 material condition was adequate. Licensee self assessment of maintenance was effective. In addition to normal core inspections, an initiative inspection is planned in January 1999 to review maintenance planning and implementation.
In the Engineering area, management continues to provide necessary leadership in important areas. Many programs have been improved but small pockets of weakness still exist. System engineering was effective in resolving most emerging issues. Design engineering has also improved but some engineering products did not address all the technical issues, Your performance during the previous assessment period warranted additional inspection effort above the core inspection program. During this period, an extraordinary number of modifications have been completed to improve plant performance. Therefore, continued additional inspection effort will consist of two followup engineering inspections that are planned in February and March 1999 to reduce the backlog of NRC open items.
In the Plant Support Area, the radiation protection (RP) program continues to very effectively meet its limited challenges associated with the long term shutdown. Training proficiency of RP technicians was poor. The licensee has updated the Offsite Dose Calculation Manual (ODCM) parameters and a new individual was assigned responsibility for the program. The licensee has implemented an adequate security program. The overall performance of the plant's emergency response organization to a April 1998 Emergency Preparedness (EP) exercise was good. EP program performance is improving. Performance of the fire protection program, based on resident inspector observations, was adequate. In addition to normal core inspections, an
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3 radioactive effluents inspection is planned to review the licensee's implementation of the ODCM which includes their offsite dose projection calculation methodology.
2 Enclosure 1 contains a historical listing of plant issues, referred to as the Plant issues Matrix l (PIM), that were considered during this PPR process to arrive at an integrated view of licensee i performance trends. The PIM includes items summarized from inspection reports or other l docketed correspondence between the NRC and (licensee name). The NRC does not attempt j to document all aspects of licensee programs and performance that may be functioning appropriately. Rather, the NRC only documents issues that the NRC believes warrant 1 i management attention or represent noteworthy aspects of performance. In addition, the PPR may also have considered some predecisional and draft material that does not appear in the
, attached PIM, including observations from events and inspections that had occurred since the
- last NRC inspec4on report was issued, but had not yet received full review and consideration. 1 i
This material will be placed in the PDR as part of the normalissuance of NRC inspection reports I i and other correspondence.
l This letter advises you of our planned inspection effort resulting from the (plant name) PPR j review. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite, Enclosure 2 details our inspection plan for the next 6 months. Also included in the plan are NRC i
non-inspection activities. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. !
i Resident inspections are not listed due to their ongoing and continuous nature.
a We willinform you of any changes to the inspection plan. If you have any questions, please contact (DRP Branch Chief) at (telephone number). i l
(Signed by), Chief ,
Reactor Projects Branch I Division of Reactor Projects Docket Nos. 50-ABC,50-XYZ License Nos. NPF-0, NPF-00
Enclosures:
- 1. Plant issues Matrix
- 2. Inspection Plan ec:
Normal cc list + any additional SALP recipients Distribution:
Normal distribution list
+ Chief, NRR/ DISP /PIPB
+ Chief, OEDO/ROPMS
+ TBoyce, NRR/ DISP /PIPB
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