ML13155A141
| ML13155A141 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/28/2013 |
| From: | Limpias O Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| nls2013052 | |
| Download: ML13155A141 (5) | |
Text
N Nebraska Public Power District Always there when you need us NLS2013052 May 28, 2013 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-001
Subject:
Follow-Up to 30-Day Written Response Regarding Substantive Cross-Cutting Issues Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
- 1. Letter from the U.S. Nuclear Regulatory Commission to Oscar A. Limpias, Nebraska Public Power District, dated March 4, 2013, "Annual Assessment Letter for Cooper Nuclear Station (Report 05000298/2012801)"
- 2. Letter from Nebraska Public Power District to the U.S. Nuclear Regulatory Commission, dated April 1, 2013, "30-Day Response Regarding Substantive Cross-Cutting Issues" (NLS2013041)
Dear Sir or Madam:
In Reference 1, the Nuclear Regulatory Commission (NRC) determined that the performance of Cooper Nuclear Station (CNS) in the most recent assessment period was in the Licensee Response Column of the NRC's Reactor Oversight Process Action Matrix. However, a Substantive Cross-Cutting Issue (SCCI) was identified in the P. 1 (c) area associated with the corrective action component related to the thoroughness of problem evaluations such that resolutions address causes and extent of condition. An SCCI was also identified in the H.1(b) area associated with the decision-making component related to conservative assumptions.
Additionally, an SCCI was identified in the H.2(c) area associated with the resources component related to design, procedures, and labeling.
As committed in Reference 2, the purpose of this letter is for Nebraska Public Power District (NPPD) to provide the NRC with NPPD's details regarding additional corrective actions to address thethree open SCCIs and to provide a schedule outlining readiness for inspection of the corrective actions taken.
As stated in Reference 2, NPPD has created and is implementing an improvement plan that addresses five key areas. The areas identified in the plan include Organizational Alignment and the Corrective Action Program (CAP). This plan will address several of the performance areas identified in the SCCIs with a specific focus on CAP implementation and execution.
00 COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 O J.
Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com
NLS2013052 Page 2 of 2 NPPD performed a root cause evaluation to identify corrective actions needed to address each of the SCCIs. The results of that root cause evaluation are provided in the attachment to this letter.
As requested in Reference 1, NPPD performed an independent assessment of the safety culture at CNS. That assessment was performed the week of May 6, 2013.
This letter does not contain any regulatory commitments.
Should you have any questions or require additional information, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.
Sincerely, Oscar A. Limpigs Vice President - Nuclear and Chief Nuclear Officer hJo
Attachment:
Summary of Action Plan and Root Cause Evaluation Results for Cooper Nuclear Station Substantive Cross-Cutting Issues in Human Performance [H. 1(b), H.2(c) and Problem Identification and Resolution [P. 1(c)]
cc: Regional Administrator, w/attachment USNRC Region IV Cooper Project Manager, w/attachment USNRC NRR Project Directorate IV-I Senior Resident Inspector, w/attachment USNRC - CNS NPG Distribution, w/attachment CNS Records, w/attachment
NLS2013052 Attachment Page 1 of 3 Summary of Action Plan and Root Cause Evaluation Results for Cooper Nuclear Station Substantive Cross-Cutting Issues in Human Performance H.1(b), H.2(c) and Problem Identification and Resolution [P.l(c)]
In the Nebraska Public Power District Cooper Nuclear Station (CNS) Annual Assessment Letter (ADAMS Accession Number ML13063A076) dated March 4, 2013, the Nuclear Regulatory Commission (NRC) identified a Substantive Cross-Cutting Issue (SCCI) in the area of Human Performance associated with the Conservative Assumptions aspect of the Decision-Making component [H. 1(b)]. An SCCI was determined to exist because the NRC had a concern that the corrective actions CNS implemented did not demonstrate sustainable performance improvements by a notable reduction in the number of inspection findings with the same common theme.
The NRC also identified an SCCI in the area of Human Performance associated with the Design, Procedures & Labeling aspect of the Resources component H.2(c). An SCCI was determined to exist because established corrective actions to address the theme were not effective and the NRC had concerns with the scope of effort in addressing the theme.
In addition, the NRC identified an SCCI in the area of Problem Identification and Resolution aspect of the Corrective Action Program component [P. 1 (c)]. An SCCI was determined to exist because current performance did not show sustainable improvement in this theme over the last three assessment periods.
These issues were entered into the CNS Corrective Action Program as Condition Reports CR-CNS-2013-01740, CR-CNS-2013-01741, and CR-CNS-2013-01742. It was determined that a formal Root Cause Evaluation was needed to address the SCCIs. As such, a Root Cause Team was assembled and as a result, identified two root causes for the condition.
The first root cause is CNS standards related to the resolution of apparently low significance regulatory issues are low and do not meet industry expectations. This manifests in a lack of urgency to fully understand and resolve SCCIs and NRC Findings. A second root cause was determined to be the CNS Engineering Department and the CNS Operations Department are not adequately proficient in the application of the Design Basis of the plant. Weak Design Basis knowledge, together with limited experience related to the application of the Design Basis, particularly in the Engineering Department, result in the reduced level of proficiency.
Three contributing causes were identified. The first contributing cause is communication with the station NRC Resident Inspectors is not fully effective. The second contributing cause is Performance Indicators related to SCCIs and NRC Findings are not included in normal management reviews of station performance. This reduces opportunities for identification and understanding of these trends and the assignment of accountability to resolve them. The third contributing cause is Condition Reports documenting Non-Cited Violations (NCVs) and other NRC Findings are typically classified at a level too low to drive evaluation for underlying process, program, and organizational factors that contributed to a problem becoming an NCV or other NRC Finding.
NLS2013052 Attachment Page 2 of 3 Corrective Action Plan Summary To address the low standard for resolving significant regulatory issues, a root cause evaluation will be performed on Condition Reports documenting an SCCI. In addition, an apparent cause evaluation will be performed on Condition Reports documenting any NCV requiring an evaluation of the underlying causes that resulted in the condition becoming an NCV, including why the issue that resulted in the NCV was not self-identified. On a monthly basis at a management meeting, Performance Indicators for SCCIs and NCVs will be reviewed. Also, a presentation of the findings from the Root Cause evaluation for the SCCIs will be made to management at CNS and to the Nebraska Public Power District Executive Planning Council.
Training will be developed and delivered to managers, supervisors, and department performance improvement coordinators in Trending Techniques that facilitate identification of the collective significance of groups of low significance issues.
To address the inadequate proficiency in the application of the Design Basis of the plant, training will be developed on plant design basis, USAR, and Technical Specifications with a focus on the interrelationship of these documents. This training will be delivered to Engineering incumbents, Shift Technical Engineers and Shift Managers. A job analysis will be conducted to determine initial and continuing training requirements for these groups. A pool of mentors will be established and from this pool, assignments will be made for the mentors to review key civil and mechanical design analysis products. In addition, the Senior Reactor Operators and Shift Technical Engineers will be given Operability Determination Training. A topic analysis will be conducted to determine whether all required knowledge and skills are adequately addressed in the engineering training programs and the operations training programs.
In addition, an on-going Licensing/NRC Communication plan will be established and implemented.
These corrective actions are currently scheduled to be complete by the end of the fourth quarter.
As such, CNS will be ready for inspection of the corrective actions by December 31, 2013.
CNS Performance Improvement CNS recognizes that organizational alignment is required to ensure early detection and resolution of challenges to ensure minimal impact. As such, in an effort to improve performance at CNS, an improvement plan that addresses five key areas was created and is being implemented. These areas are Organizational Alignment, Corrective Action Program Performance, Modification Implementation, Radiological Performance, and Outage Execution.
CNS developed this improvement plan using guidance from the Institute of Nuclear Power Operations document, "An Implementation Frameworkto Significantly Improve Nuclear Plant Performance".
While many of the actions in the improvement plan are complete, certain outage related actions will remain open until near or after the next refueling outage scheduled for September 2014.
NLS2013052 Attachment Page 3 of 3 Independent Safety Culture Assessment An independent safety culture assessment was performed at CNS the week of May 6, 2013.
Upon receipt of the assessment report, negative findings and observations will be entered into the Corrective Action Program for resolution.