ML023010062

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Letter to Ellis W. Merschoff from David L. Wilson, Subject Transmittal of the Strategic Improvement Plan (TIP) Revision 1 Cooper Nuclear Station
ML023010062
Person / Time
Site: Cooper 
(DPR-046)
Issue date: 06/10/2002
From: Denise Wilson
Nebraska Public Power District (NPPD)
To: Merschoff E
Region 4 Administrator
References
FOIA/PA-2003-0001
Download: ML023010062 (5)


Text

Nebraska Public Power District Nebraska's Energy Leader NLS2002029 June 10, 2002 Ellis W. Merschoff Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011

Dear Mr. Merschoff:

Subject:

Transmittal of The Strategic Improvement Plan (TIP) Revision I Cooper Nuclear Station, NRC Docket 50-298, DPR-46 The purpose of this letter is to submit The Strategic Improvement Plan (TIP) Revision I for Cooper Nuclear Station (CNS) to the Nuclear Regulatory Commission (NRC). The plan was prepared to address requirements of the NRC Reactor Oversight Process Action Matrix for a plant in the repetitive degraded cornerstone status. CNS entered this status on April 1, 2002.

TIP will be used during conduct of the NRC Inspection Procedure (IP) 95603 team inspection due to begin on June 24, 2002.

TIP is a long-term, broad-based plan that contains corrective actions and enhancements that will help lead CNS toward excellence through a phased approach. TIP Revision I was developed based on an evaluation of major assessments and improvement plans datingfrom 1993. Action plans were developed to address the extent of condition and the related causal factors.

TIP is a "living document" subject to revision and updating as future evaluations, assessments and issues dictate. The plan will be completed in phases until it is demonstrated that each action plan has addressed the underlying cause(s) of the stated problems from both an immediate and recurrerice prevention perspective. Actions may be added to TIP to ensure the successful outcome of action plans or to address emerging issues.

Prior to CNS entering the repetitive degraded cornerstone status, Nebraska Public Power District (NPPD) had determined that an improvement plan was necessary to focus personnel on immediate improvements in CNS performance. Following the refueling outage in January 2002, CNS management began developing the improvement plan. The initial purpose of TIP Revision 0, issued on April 8, 2002, was to accomplish specific, near term objectives designed to arrest Cooper Nudear Station P.O. Box 96/ Brownvile. NE 6832M-0098 Telephone: (402) 825-3811 /Fax (402) 825-5211 http-//www nppd corn

NLS2002029 Page 2 of 3 degrading performance. Evaluation and assessment subsequent to issuance of Revision 0 have resulted in the development of TIP Revision 1, which has broader scope.

TIP Revision 0 initiated improvement actions in a number of focus areas, including:

(1) Organizational Effectiveness (a) Management Effectiveness (b) Human Performance Fundamentals (c) Corrective Action Program Effectiveness (2) Emergency Response Organization Performance (3) Operational Focus & Alignment (4) Training Program (5) Outage Planning and Effectiveness (6) On-line Work Management (7) Equipment Reliability (8) Engineering Programs (9) Fiscal Discipline The results of the previously mentioned evaluation of past major assessments and improvement plans caused CNS management to increase the number of focus areas to 18 in TIP Revision 1.

These focus areas have been aligned within the following four "Pillars of Excellence":

(1) Organizational Excellence (2) Operational Excellence (3) Equipment Excellence (4) Training Excellence.

Benchmarking of other industry improvement and business plans have demonstrated that these Pillars of Excellence generally represent those fundamental areas of plant operation that must be present to sustain top-level performance.

TIP Revision 2 will be submitted after completion of the NRC IP 95003 inspection and will serve as a basis for the anticipated NRC Confirmatory Action Letter. Revision 2 will contain the results of a detailed resource prioritization, estimating, planning and scheduling process. Some start and completion dates in Revision I may be adjusted through this process. Revision 2 will also include enhancements from continuing evaluations and additional actions resulting from the NRC inspection and emerging issues. Specific performance improvement objectives or actions contained in Revision 2 will be identified as regulatory commitments. NPPD will submit TIP Revision 2 to the NRC following receipt of the NRC IP 95003 inspection report.

NPPD Quality Assurance will perform ongoing surveillances of TIP implementation throughout the implementation period.

NLS2002029 Page 3 of 3 NPPD and the management of this station are committed to the individual, team and organizational behavior changes necessary to ensure successful results with both TIP and the longer-term transition to excellence in station performance.

Should you have any questions concerning this matter, please contact me at 402-825-2760.

Sincerely, David L. Wilson Vice President - Nuclear

/jrs Attachment cc:

U.S. Nuclear Regulatory Commission Att: Document Control Desk Washington D.C. 20555-0001 Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution

I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS Correspondence Number:

NLS2002029 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE Submit Revision 2 of TIP after completion of the NRC IP 95003 inspection and receipt of the inspection report.

Revision 2 will contain the results of a detailed resource N/A prioritization,estimating, planning and scheduling process.

Specific performance improvement objectives or actions contained in Revision 2 will be identified as regulatory commitments.

I PROCEDURE 0.42 REVISION 11 PAGE 13 OF 16 i

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NLS2002029 ATTACHMENT The Strategic Improvement Plan, Revision I Cooper Nuclear Station Docket 50-298, License DPR-46