ML030710168
| ML030710168 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/05/2003 |
| From: | Nebraska Public Power District (NPPD) |
| To: | Thadani M Office of Nuclear Reactor Regulation |
| References | |
| R129-0100EF | |
| Download: ML030710168 (14) | |
Text
R129 -0100EF Record Series 214 Cooper Nuclear Station DOCUMENT TRANSMITTAL Date March 05, 2003 Page 1 of I Document To: Mohan Thadani TIP Action plan 5.3.2.1 From: Document Control Cooper Nuclear Station Document Control Office, P.O. Box 98, Brownville, NE 68321
[Controlled Document E] Drawing El Specification [] Procedure E]Other Number Document Rev. No. Document Title / Remarks Copies Number or Date 1 15 Rev. 2a TIP Action Plan 5.3.2.1 I hereby acknowledge receipt and incorporation of the above listed pages ! documents. The superseded pages /
documents have been destroyed, stamped "superseded", or returned. Sign and return transmittal withinten (1 0) 1 working days. jAb)L Signed: Date:
Electronic Form PROCEDURE 1.10 Please ensure this form is the same as in the lastest procedure revision.
I ATTACHMENT 4 FILING INSTRUCTION ILLUSTRATION NOTE: These changes update TIP Rev. 2 and are administrative in nature such as changes in end dates and updates to action steps and deliverables.
FILING INSTRUCTIONS Remove Insert From Tab 5, remove TIP Action Plan Replace with TIP Action Plan 5.3.2.1, Rev.
5.3.2.1, Rev. 2, dated 11/20/2002. 2a, dated 2/27/2003.
I PROCEDURE 1.10 I REVISION 11 1 PAGE 7 OF 10 j
TIP ACTION PLAN PILLAR OF EXCELLENCE: Equipment Excellence FOCUS AREA: Programs ACTION PLAN TITLE: Engineering Programs ACTION PLAN NUMBER: 5.3.2.1 COMPLETION DATE: 1Q/07 ACTION PLAN OWNER: Scott Freborg APPROVAL: ,*_v .' Z " ,ie i FOCUS AREA OWNER: Allen Williams APPROVAL: .i.
PROBLEM STATEMENT:
The performance of Cooper Nuclear Station (CNS) Engineering Programs has historically lacked sustained effectiveness.
CAUSAL FACTORS:
- 1. Ownership of Engineering Programs has been loosely defined or not defined at all. (Actions 1, 2, 3)
- 2. The expectations of Engineering Program owners were not clearly defined or enforced. (Actions 1, 2, 9)
- 3. Organizational depth in Engineering Programs has been lacking. (Actions 5, 6, 7)
- 4. The quality and frequency of self-assessments has been lacking. (Actions 1, 2, 4, 10, 11, 12, 13)
- 5. Oversight and Implementation of the CNS Engineering Programs has been less than adequate. (Action 8, 14a, 14b, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42)
OBJECTIVES:
- 1. Procedure 0-CNS-12, CNS Program Administration, is closely aligned with the industry with respect to proper scope of Engineering Programs and the proper standards and expectations for Engineering Program oversight and management.
- 2. The full extent of condition in Engineering Programs is identified through completion of the remaining program self-assessments and interface assessments.
- 3. High priority corrective actions resulting from the self-assessments, program benchmarks, and the interface assessments are identified and implemented.
- 4. Independent verification of effectiveness of program corrective actions and program health ratings is established. Programmatic controls to insure sustained Engineering Program health beyond The Strategic Improvement Plan closure are established.
- 5. Organizational depth in Engineer;ng Programs is established.
Page 1 of 12 Action Plan 5.3.2.1 Revision 2a 2/27/03
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- 6. Implementation of required Engineering Program related modifications and projects.
- 7. Adequate and consistent management oversight of Engineering Program health is established.
- 8. Improvements in CNS Program Management through implementation of industry benchmarking recommendations.
NO. ,ACTION CNS ENGINEERING PROGRAM INFRASTRUCTURE
,, ACTION OS OWNER STARTDATE ENDDATE DELIVERABEE I Benchmark Procedure 0-CNS-12 against best industry practices in the area of major program scope and standards and expectations for Engineering Program management.
(This action is tied to Action Plan 5.1.1.9.) Benchmark report in accordance 0-CNS-06.
Beth Hannaford Complete with Procedure be performed in Benchmarking is to accordance with 0-CNS-06, Guideline for Benchmarklng. Benchmarking goals and objectives will be established in accordance with the requirements by 0-CNS-06.
With input from the benchmark report, revise Revised Procedure O-CNS-12 CNS Procedure 0-CNS-12 to Include the proper which will reflect scope of scope of Engineering Programs and the engineering programs 2 appropriate standards and expectations for Beth Hannaford Complete consistent with the industry, Engineering Program management. and the associated standards and expectations for program (This action is tied to Action Plan 5.1.1.9.) implementation.
Action Plan 5.3.2.1 revised as Review and revise, as necessary, Action Plan required, to incorporate Scott Freborg 4Q/02 1QO03 improvements identified through 3 5.3.2.1 Rev. 2 to reflect applicable changes completion of benchmarking implemented as a result of Action 2.
and revision to 0-CNS-12.
Revised Procedure 0-CNS-12 to Establish a specific standard for sustained Beth Hannaford 2Q/03 3Q/03 include specific standards for quality Engineering Program self-assessments. sustained quality Engineering Program self-assessments.
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K TIP ACTION PLAN NO. ACTION ACTION OWNER START DATE END DATE DELIVERABLE Develop and approve Training Qualification Descriptions (TQDs) for areas within Engineering Programs lacking formal qualification requirements. These include:
. Snubber Ken Thomas 2Q/03 3Q/03 Approved TQD for stated o Repairs and Replacements, and programs.
- Paintings and Coatings Establishment of these specific qualifications wi!l be utilized to increase technical proficiency and provided increased organizational depth.
Fully qualified back-up program Establish organizational depth for the major Jim Salisbury 4Q/02 4Q/04 owners for each major Engineering Programs listed in 0-CNS-12. Engineering Program in accordance with applicable TQD.
Standard for maintaining Revise CNS Procedure 0-CNS-12 to irclude a Beth Hannaford 2Q/03 3Q/03 organizational depth in standard for maintaining organizational depth. Engineering Programs included in procedure 0-CNS-12.
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TIP ACTION PLAN NO. ACTION ACTION OWNER0 START DATE ENDDATE b DELIVERABLE,:,,
Revised Procedure O-CNS-12 Develop a process that will insure adequate which includes a process for 8 and consistent management oversight of Jim Salisbury 20J03 30Q03 adequate and consistent program health. management oversight of I_ rogram health.
Revise 0-CNS-22, Conduct of Engineering, to align with standards and expectations established in 0-CNS-12 for engineers assigned Procedure 0-CNS-22 revised to 9 to Engineering Programs. This includes specific Jim Salisbury 1Q/03 2Q/03 align with 0-CNS-12.
expectations for Engineering Program engineers in providing field support.
CNS ENGINEERING PROGRAM ASSESSMENTS Complete detailed technical self-assessments of the following programs in 2002:
"* Boiling Water Reactor Vessel and Internals Project (BWRVIP),
"* Erosion/Corrosion (Flow Accelerated Self-Assessment reports Ken Thomas Complete prepared in accordance with 0 10 Corrosion (FAC)), CNS-25. Notifications written for o 10 CFR 50, Appendix J, and
- Welding/repair and replacement. deficiencies/conditions.
Procedure O-CNS-25, Self Assessment, is used for assessment methodology and approach. I ý Page 4 of 12 Action Plan 5.3.2.1 Revision 2a 2/27/03
TIP ACTION PLAN NO. ACTION ACTION OWNER, START DATE ,,'ENDDATE- -DELIVERABLE.",
Complete detailed technical self-assessments of the following programs in 2003.
- Heat Exchangers,
- Check Valves, Self-Assessment reports
- Painting and Coatings, and prepared in accordance with 0 11 ° Probalistic Risk Assessment (PRA) Scott Freborg 2QJ03 40Q03 CNS-25. Notifications written for deficiencies/conditions.
Procedure 0-CNS-25, Self Assessment, is used for assessment methodology and approach.
The focus of these technical self-assessments is both regulatory compliance and technical adequacy of program elements.
Complete interface assessments of the following programs in 2003.
- Erosion/corrosion (FAC),
- Welding/repair and replacement,
- Inservice Inspection (ISI), Interface assessment reports
- Inservice Testing (IST), prepared in accordance with 0 12
- Motor Operated Valves (MOVs), and Ken Thomas 2Q/03 4Q/03 CNS-25. Notifications written
° Fire Protection (FP) for deficiencies/conditions.
The interface assessment is not expected to specifically cover the compliance aspects of the program being assessed, however the interface assessment could identify gaps in program interfaces that could affect procedural and regulatory compliance.
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l TIP ACTION PLAN
- NO. *- , , ACTION, f , '7&ACTION
" OWNER.': - STARTDATETE ' E, ;*DELI.:"VERABLEE Complete interface assessments of the following programs in 2004.
"* Heat Exchangers
"* Snubbers
- Painting and Coatings Interface assessment reports
- PRA, and prepared in accordance with 0 13
- Air Operated Valves (AOV) Scott Freborg 1Q/04 20/04 CNS-25. Notifications written for deficiencies/conditions.
The interface assessment is not expected to specifically cover the compliance aspects of the program being assessed, however the interface assessment could identify gaps in program interfaces that could affect procedural and regulatory compliance.
CNS ENGINEERING PROGRAMS CORRECTIVE ACTION IMPLEMENTATION BWRVIP Identify and implement high priority corrective Action plan developed and high actions resulting from the BWRVIP Program priority Corrective Action technical self-assessment and the interface Program (CAP) items associated assessment. Perform required BWRVIP with BWRVIP Program 14a Program inspections in Refueling Outage 21 Mark Lyman 2Q/02 3Q/03 implemented during RE 21.
(RE 21). Target health goal is sustained GREEN by 7/05.
In addition, identify and schedule the required BWRVIP inspections for Refueling Outage 22.
14b iReuinOuae2(R22.Mark Perform required BWRVIP Program inspections Lyman 3Q/03 40./04 Required BWRVIP inspections Program completed in RE 22.
in Refueling Outage 22 (RE 22). n opee nR 2 Develop a separate BWRVIP Program BWRVIP Program document in 15 document and implementing procedure. Mark Lyman Complete place and implementing document __nd__implementing__procedure._procedure issued.
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>i N.``* )ACTION +, ;,ACTION OWNER. ISTART, DATE, 1.. .ATE 7 ° DELIVERABLE
- 4y" EROSION/CORROSION PROGRAM Action plan developed and high Identify and Implement high priority corrective priority CAP items associated 16 actions resulting from the Erosion/Corrosion Mark Lyman 2Q/03 2Q/04 with Erosion/Corrosion Program Program technical self-assessment and the implemented. Target health interface assessment. goal is sustained GREEN by 7/05.
10CFRS0 APPENDIX J PROGRAM Action plan developed and high Identify and implement high priority corrective priority CAP items associated actions resulting from the Appendix J Program Scott Freborg 2Q/03 2Q/04 with Appendix J Program 17 technical self-assessment and the interface implemented. Target health assessment. goal is sustained GREEN by 7/05.
WELDING/REPAIR AND REPLACEMENT PROGRAM Action plan developed and high and implement high priority corrective priority CAP items associated Identify Identions resulting implemten WeinghpReaitretivwith Welding/Repair and 18 actions resulting from the Welding/Repair and Doug Boes 2Q/03 20/04 Replacement Program Replacement Program technical self- implemented. Target health assessment and the interface assessment. goal is sustained GREEN by 7/05.
HEAT EXCHANGER PROGRAM Action plan developed and high Identify and implement high priority corrective priority CAP items associated actions resulting from the Heat Exchanger with Heat Exchanger Program Program technical self-assessment and the Scottimplemented. Target health interface assessment. goal is sustained GREEN by 7/05.
SNUBBER PROGRAM Action plan developed and high Identify and implement high priority corrective priority CAP items associated 20 actions resulting from the Snubber Program Doug Boes 2Q/03 3Q/04 with Snubber Program technical self-assessment, and the interface implemented. Target health assessment. goal is sustained GREEN by 7/05.
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C TIP ACTION PLAN I - C
- NO *. "ACTIONf* *: $', , ACTION1 OWNER ISTART DATE, 1END DATE* I2.t DELIVERABLE >
ELECTRICAL BREAKERS PROGRAM 21 Deleted I Breakers refurbished and 22 Implement the 4160 Volt Breaker Jim Dykstra 2Q0.2 2Q/03 installed in accordance with Refurbishment Project Plan. 4160 Volt Breaker Refurbishment Project Plan.
Create and approve the 480 Volt Circuit 23 Breaker Replacement and Refurbishment ed Hough Complete Approved project plan for 480 Project Plan per Procedure 0-CNS-18, Project Volt Circuit Breakers.
Management.
Implement 480 Volt Circuit Breaker Breakers refurbished in ,
24 Replacement and Refurbishment Project Plan Jim Dykstra 20Q02 1Q/07 accordance with 480 Volt Circuit scope. Breaker Replacement and Refurbishment Project Plan.
CHECK VALVE PROGRAM Action plan developed and high Identify and implement high priority corrective priority CAP items associated 25 actions resulting from the Check Valve Program Duane Stuhr 2Q/03 3Q/04 implemented. Target health technical and the interface se'f-assessment. goal is sustained GREEN by 7/05.
PAINTING AND COATINGS PROGRAM Action plan developed and high Identify and implement high priority corrective priority CAP items associated actions resulting from the Painting and Romeo Serranzara 2Q/03 3Q/04 with Painting and Coatings Coatings Program technical and the interface Program implemented. Target self-assessment. health goal is sustained GREEN by 7/05.
PRA PROGRAM Action plan developed and high priority CAP items associated Identify and implement high priority corrective Kent Sutton 2Q/03 3Q/04 with PRA Program 27 actions resulting from the PRA Program implemented. Target health technical and the interface self-assessment.
goal is sustained GREEN by
____________________________________________________ __________ __________7/05.
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ýNO.Uy 2 -A'~ QWATINOWNERKTT7STARTDATET , ENDAT~
M-IN;~?~.~ DLIE BE 5 MOV PROGRAM Action plan developed and high priority CAP items associated with MOV Program Identify and implement high priority corrective Duane Weninger 2QJ01 20Q04 i th Targral 28 actions resulting from the MOV Program 28interf~ace assessment. implemented. Target health goal is sustained GREEN by 7/05.
Requlatory Commitment Calculations completed and 29 Complete MOV Program Category II Design Duane Weninger 4Q/01 20303 approved.
Basis Calculations.
30Regulatory Commitmert Weninger 03 303 Completed work packages for Perform baseline testing of Category II Valves. testing of Category II Valves.
Regulatory Commitment Revised MOV Program 31 Duane Weninger Complete Document which includes Include Category II MOVs in the MOV Program. I Category II MOVs.
AOV PROGRAM Action plan developed and high priority CAP items associated with AOV Program Identify and implement high priority corrective John Oswald 40J01 1Q/05 implemented. Target health 32 actions resulting from the AOV Program interface assessment. goal is sustained GREEN by 7/05.
Complete Category I System Level Calculations completed and 33 Review/Component Level Review (SLR/CLR) John Oswald 2Q/02 3Q/03 approved.
calculations.
John Oswald 1Q/03 2Q/03 Completed work packages for Perform baseline testing of Category I AOV Category I AOV Valve Testing.
34_Valves.
Calculations completed and John Oswald 4Q/03 3QJ06 approved.
35 Complete Category II SLR/CLR calculations.
rform baseline testing of Category II Valves. John Oswald 4Completed work packages for 36 Perform h 4Q/04 1Q/07 Category II AOV Valve Testing.
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-A TIP ACTION PLAN NO. . ..... ACTION .. . . ACTION OWNERQr, :START:DATE' *END*DATE, DELIVE' B E '*
ISI PROGRAM Action plan developed and high Identify and implement high priority corrective priority CAP items associated 37 actions resulting from the ISI Program interface Mark Lyman 2Q/01 20J04 with ISI Program implemented.
assessment. Target health goal is sustained GREEN by 7/05.
IS-T"PROGRAM Action plan developed and high Identify and implement high priority corrective priority CAP items associated 38 actions resulting from the IS- Program Tom Robinson 2Q/01 2QJ04 with IST Program implemented.
interface assessme:nt. Target health goal is sustained GREEN by 7/05.
FPPROGRAM Action plan developed and high Identify and Implement high priority corrective priority CAP items associated 39 actions resulting from the FP Program interface Ray Dyer 20J01 20/04 with FP Program implemented.
assessment. Target health goal is sustained I I .GREEN by 7/05.
EQUIPMENT QUALIFICATION (EQ) IMPROVEMENT PROJECT Reaulatory Commitment All project milestones Jim Lechner 2Q/00 2QJ03 associated with restoring 40 Complete implementation cf those portions of completed.
the EQ Improvement Project as necessary to completed.
establish 50.49 compliance.
All project milestones complete, all project deliverables issued or Complete implementation of the EQ Jim Lechner 2Q/00 1Q/04 implemented. Target health Improvement Project. goal is sustained GREEN by project completion date.
0-CNS-12 COMPLIANCE Page 10 of 12 Action Plan 5.3.2.1 Revision 2a 2/27/03
TIP ACTION PLAN NO. . ACTION, ACTION OWNER-, START DATE- ENDDATE DELIVERABLE Program Health Report for each CNS Program Activities listed in O-CNS-12 of the 19 CNS Programs 2Q/03 1Q/04 42 Attachment 2 are brought into compliance with Allen Williams 0-CNS-12, latest effective revision, documents compliance with 0 CNS-12 latest effective revision.
GENERAL Training of targeted personnel from the Documentation that CNS engineering department, as identified by CNS Engineering personnel impacted 4 Training Procedure 1.12, Document Review Beth Hannaford 2Q/03 3Q/03 by the procedural revisions are Committee. identified and trained in accordance with the systematic approach to training.
Change Manaaement Establish a Change Management Plan in A written Change Management 44 accordance with the CNS Change Management Beth Hannaford 40J02 20J03 Plan approved by the Assistant Guideline that communicates and reinforces Vice-President.
the changes to expectations, requirements, roles and responsibilities.
Monitorinq - Self-Assessments Documentation that the Perform Interim Self-Assessments to determine Interim Assessments were the effectiveness of the individual actions taken performed and determined the to improve Engineering Programs. Revise effectiveness of actions taken to 45 Action Plan based upon Interim Assessment, as Scott Freborg 2QJ03 2Q/06 improve the Engineering required, to improve effectiveness of Programs. Action Plan would be Engineering Programs. Self-Assessments to be revised as required based upon performed in accordance with 0-CNS-25, Self results of the Interim Assessment, as supplemented by the Generic Assessments.
Program Self-Assessment Guideline.
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TIP ACTION PLAN NO. ACTION ACTION OWNER, START DATE END DATE, ,- ,,::;bDELIVERABLE Verification - Final Assessment Documentation that the Final
// Effective Assessment was Perform Final Effective Assessment in performed and established that 46 accordance with O-CNS-25, Self-Assessment, Scott Freborg 4Q006 1Q007 the required actions have with assistance of Quality Assurance, to improved Engineering Programs establish that the required actions have and that the end state is improved Engineering Programs and the end consistent with the stated state is consistent with the stated Objective. Objective.
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