ML19332D453
| ML19332D453 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/22/1989 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8912010224 | |
| Download: ML19332D453 (25) | |
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In Reply Refer To:
Docket: 150-298 e
I Nebraska Public Power District ATTN:. George A. Trevors 4
Division Manager - Nuclear Support
. P.O. Box 499:
Colunbus, Nebraska-68602-0499 Gentlemen:
?This refers to the meeting conducted November 1,1989, at Cooper Nuclear Station between members of your staff and Region IV representatives, as identified in the attached Attendance List. This meeting related to NPPD's program improvements in response to the Systenatic Assessment of Licensee Performance for the period February 1,1988, through April 15',1989(NRCInspection Report 50-298/89-12) dated June 20, 1989.
The topics covered during your presentation are described in the enclosed Meeting Sununary.
It is our opinion that this meeting was beneficial and has provided a better understanding of the actions-you are taking to improve your overall performance in safety assessneat and quality verification.
In accordance with Section 2.790 of the NRC's " Rules of Practice." Part 2 Title 10. Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room, Should you _have any questions concerning this matter, we will be pleased to o
discuss them with you.
L Sincerely, u
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gD01o22 092Jan hamuel J. Collins, Director OM8 G
Division of Reactor Projects
Enclosure:
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Meeting Sunnary w/ attachments cc w/ enclosure:
Nebraska Public Power District ATTN:
G. D. Watson, General Counsel P.O. Box 499 Columbus, Nebraska 68601 f'/
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GLConstable JCollins 11/ /89 11/P/89
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- Cooper Nuclear Station
. ATTN: Guy R. Horn, Division,
t Manager of Nuclear Operations P.O. Box 98
'Brownville, Nebraska 68321 Nebraska Department of Ensironmental Control ATTN: Dennis Grams, Director P.O. Box 98922 Lincoln, Nebraska 68509-8922
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f Nemaha ' County. Board of Comissioners ATTN:. Larry Bohlken, Chairman
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Nemaha County Courthouse 1824 N Stevet.
Auburn.. Nebraska :68305
~ Department of, Health Division of Radiological Health ATTN: Harold Borchart Director
'301 Centennial Mall, South-s
,P.O.' Box 95007
' Lincoln, Nebraska'~68509-5007 Kansas Radiation Control' Program Director MpWS5(Ii457Ts bec distrib. by RIV:
R. D.' Martin Resident Inspector Section Chief (DRP/C)
Lisa Shea, RM/ALF g
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DRSS-FRPS-MIS System
.RIV File Project Engineer (DRP/C)
RSTS' Operator DRP l;
P. O'Connor. NRR Project Manager (MS:
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MEETING
SUMMARY
LLicensee:
Nebraska Public Power District Facility:
Cooper Nuclear Station License No.:
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Docket No.:
50-298
Subject:
QUALITY.0VERSIGHT ENHANCEMENTS l
On November 1,1989, representatives of NPPD met with Region IV personnel at l
Cooper Nuclear Station to discuss NPPD's program improvements in response to the Systematic Assessment of Licensee Perfonnance. The licensee discussed plans to improve performance in the arwa of safety assessment and quality t
verification. Topics discussed are described in the attached licensee presentation. The meeting was held at the request of the NRC. The attendance list and licensee presentation are attached to this sonenary.
Attachments:
1.
Attendance List i
2.
Licensee Presentation (NRC distribution only) t W
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. ATTENDANCE LIST Attendance at the' meeting between Nebraska Public Power District and NRC on
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November 1,1989, at the Cooper Nuclear Station:
NPPD-a L. G. Kuncl. Nuclear Power Group Manager i
G. R. Horn, Nuclear Operations Division Manager G. A. Trevors Division Manager Nuclear Support i
J. M. Meacham, Senior Mana er, Technical Support, NPPD/CNS E. M. Mace, CNS Engineerin Manager
. C; R. Moeller Technical S ff Supervisor e
NRC l
J. M. Montgomery Deputy Regional Administrator, Region IV (RIV)
G. L. Constable. Chief. Project Section C DRP W. R. Bennett, Senior Resident Inspector, RIV P. W. O'Connor, NRR Project Manager NRR/PD-IV G. A. Pick, Resident Inspector, RIV t
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August 31, 19E9 33 FOR INTER DISTRICT L. c. Kunel BUSINESS ONLY To C. A. Trevors From.
f Implementation Schedule for SRAB Improvements Subject 7
In the District's response to the NRC's 1989 SALP report we committed to a
restructure the District's off site safety oversight function (SRAB) to Specifically, we' committed to develop a improve it's effectiveness. schedule for implementation of the restructured safety over Following is a plan and schedule for these by September 1, 1989.
improvements which supports the establishment of a restructured SRAB by January 1,1990.
1.
Review and assess the safety overcight function at other utilities.
I have reviewed the charters for safety review committees at several l
utilities including those at OPPD, Iowa Electric, and Houston Power and In addition, I have reviewed a matrix of committee responsibilities, memberships, reporting relationships, etc. for several Light.
You and I met with OPPD management on August 3, 1989 to other utilities.
discuss their revised off site safety overview restructuring and I attended a nuclear safety review board meeting at HP&L's South Texas project on.
August 10,1989, Based on the material Draft a revised charter for the District's SRAB, described above, I should have a " straw man" charter for your review within 2.
two weeks (by September 15).
Resolution of comments 3.
Incorporate comments and finalize charter.
should be accomplished in an additional two weeks (by September 29).
Prepare detailed procedures for improving the SRAB review process and Once the charter is finalized, two weeks 4.safety oversight effectiveness.
should be adequate to prepare new procedures with an additional month to resolve comments (by November 17).
The Prepare Tech Spec change to correct SRAB reporting responsibility.
5.current Tech Specs incorrectly identify the "Vice President Nuclear" as In addition, revised Tech Specs will the individual to whom SRAB reports.
the restructured board (by October 31).
be required to reflect Once a revised charter is 6.
Arrange for outside membership on SRAB.
established, one month should be adequate to contract and arrange for outside participation (by November 3).
Develop a new permanent full time position for SRAB Admi.nistrator /
I 7.
This is a new position required to support SRAB.
Licensing Engineer.
expect to have this position developed, authorized, and posted by the first week in November (by November 3).
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New membership indoctrination.
Indoctrination for new members will l/
have to be developed based on the new procedures. I'm estimating two weeks f
to develop and two weeks to implement the indoctrination (by December 15).
The end' result of this plan it a new SPAB in place by January 1,1990.
I will want to discuss this plan with you by September 8.
A project schedule
-is presented below.
$RAB IMPROVEMENT $CNEDULE Jul Aug Sep oct Nov Dec
'89
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'89 REylEW Pto RAMS l'''l'''''''''''
DRAFT CHARTER l
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PROCEDURES l
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DutSIDE MEMBERSHIP l
l ADMINISTRAfDR POSITION l
DEVELOP TRAINING j
TRAlW MEMBER $
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Trevors Division Manager Nuclear Support GAT: RAD bc:.
R. A. Dieterich
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SALP SAFETY ASSESSMENT / QUALITY VERIFICATION l
l RESPONSIVENESS TO NRC CONCERNS o
SITE / GENERAL OFFICE COMMUNICATIONS
.o CORRECTIVE ACTION PROGRAMS o
SAFETY REVIEW AND AUDIT E0ARD IMPROVEMENTS
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RESPONSE
In response to the concerns regarding QA/QC effectiveness, the Quality Assurance Division has been authorized, and has budgeted for one (1) additional staff position in November, 1989, and one (1) in March, 1990.
These positions will be added to the CNS QA Staff.
STATUS:
A position of QA Engineer for Cooper Nuclear Station (Position Number 02565) was authorized July 11, 1989.
The position was posted internally (within NPPD).
No applications were received.
Presently setting up interviews with external applicants.
II.
RESPONSE
To improve the quality of QA audits the QA Division has established a technical assistance exchange program with Iowa Electric Light' and Power Company (Duane Arnold) for 1989.
The 1989 chemistry and emergency preparedness functional area audits were identified for technical assistance under this program.
The District will review the functional audit
- areas, determine the technical expertise appropriate for each audit, and ensure that each audit team contains such expertise.
STATUS:
The initial review of functional areas for determination of appropriate technical expertise to be included on internal audit teams has been completed.
Actions have been initiated with other Region IV utilities to develop an Internal Audits Technical Assistance Exchange Program.
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III.
RESPONSE
The District's peer DC program is established and described in formal procedures and is included in the nuclear J-training program.
The program. provides for independence and a means for bringing identified OC problems to the e
attention of management.
During plant outages the peer program is often augmented by a dedicated QC staff to i.
improve its effectiveness.
As a
result of the SALP concern, the peer program will be reassessed to confirm that the desired level of independence is fully achieved and the raising of problems to management attention is assured.
r STATUS:
The Oc effectiveness evaluation has been completed and is attached (M.
D.
Allen to G.
E.
Smith, QAC8900360, dated September 18, 1989).
e lk V. L. Wolstenholm Division Manager Quality Assurance VLWilm Attachment cc:
L. E. Bray - CllS G. E. Smith - CNS D. R. Robinson 1
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Nuclear Engineering and Construction Division to operability issues, reportability determinations and reporting requirements.
-o Deadlines for operability studies / determinations are now assigned and tracked within the G.O. Engineering organization o
and operability determinations as part of the design document process, f
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SITE / GENERAL OFFICE COMMUNICATIONS o
Continuing daily manager phone calls, o
Considered vidoo conferencing decided not to implement now due to limiting technology and cost, i
o 10 NED personnel - to bc staffed during first half of 19 t
o 11 eld NpG Manager's meeting in Auburn on September 14 to discuss team work and issues of mutual-interest.
o Arranging for consultant to conduct training in teamwork for senior NPG managers, December.
Looking at datos in November or early t
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i CORRECTIVE ACTION PROGRAMS i
o Revised corrective action tracking program f developed.
t or C.O. has been o
New position:
i approved and will be posted this week. Regulatory Complianc C O
., has been filled by mid December.
Expect to have position o
CA Tracking program procedure in review cycl have this improved program in operation by end of e now.
Expect to year.
o C.O. Design engineers are being scheduled for training (oriented towards the design enginroot cause Root Cause training oriented towards site oper tieer) in May 1990.
maintenance will be attended by NED supervisors in D a ons and CNS.
These training sessions are 3 days in length ecember at
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o Nuclear Configuration Management procedures hav to describe the process for the resolution e been developed developed during the design criteria documentof deficiencies
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interface with CNS reporting procedures whi h process.
These reporting criteria.
conform to NRC c
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SAFETY REVIEV AND AUDIT BOARD IMPROVEMENTS 1
o llave visited Ft. Calhoun and South Texas Project to discuss / observe off-site review process.
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llave obtained services of consultant to assist in SRAB j
o development.
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Implementation Schedule wubmitted to Nuclear Power Group Manager o
on August 31, 1989.
" Straw Man" SRAB nembership discussed at Division Managers o
meeting as follows:
tiembershin t
1.
Division Manager - QA - Chairman 2.
Division Manager - NE6C - Vice Chairman 3.
Division Manager - Nuclear Operations 4.
Division Manager - Nuclear Support 5.
Senior Manager - Operations (CNS) 6.
Nuclear Licensing & Safety Manager I
7.
Nuclear Training Manager 8.
Nuclear configuration Management Department Manager 9.
Consultant (Previous NRC Experience) 10.
Consultant (Industry Experience) a.
Senior Manager exchange with another BVR7
- Optional b.
Academic consultant?
(Peru State, eg.)
c.
Representative of IPL?
(R. Singer has B.S.
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- Still under consideration.
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t SRAB Support i
i 1,1 censing Engineer /SRAB Administrator (new position) l Safety Review Group (new position or transferred from CNS)
(Reports to SRAB Chairman)
Supervisor plus 3 Specialists I
Corrective Action Review Bcard (CARB)
This would be transferred to SRAB chairinan e
o Revised Charter in dtaft form, i
Our progress on plan is apprcximately 30 days behind schedule, e
i' May be difficult to have SRAB in place by January 1,1990, but o
should be f.n effect during first quarter.
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"!MPROVEMENT OF THE CORRECTIVE ACTIONS PROGRAM WITH EMPHASIS ON ROOT l
CAUSE DETERMINATION"
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I NOVEMBER 1,1989 E. M. MACE CNS ENGINEERING MANAGER O
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t'*C/NPPD SALP MEETING E
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SUMMARY
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CORRECTIVE /sCTION FROGRAM E
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ROOT CAUSE ANALYSIS i
D!FFICULTY IN INFORMATION RETRIEVAL t
S PERFORMANCE AREA OF SAFETY ASSESSMENT /
QUALITY VERIFICATION WEAKNESS
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ROOT CAUSE ANALYSIS FREQUENTLY INEFFECTIVE COMPLETION OF CORRECTIVE ACTION l
SALP REPORT RECOMMENDED LICENSEE ACTIONS IMPROVEMENT OF THE CORRECTIVE ACTIONS o
PROGRAM WITH EMPHASIS ON ROOT CAUSE DETERMINATION i
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CORRECTIVE ACTION PROGRAM l
ROOT CAUSE ANALYSIS (RCA) 3 1.
RESCLUTION:
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COMPLETED A 3RD PARTY REVIEW OF i
THE RCA PROCRAM o
IDENTIFIED WEAKNESSES:
o DEPTH OF THE ROOT CAUSE b
INVESTICATION IS NOT CONSISTENT PROBLEM SCOPE EVALVATION EVALUATION OF COMMON FACTORS OF SIMILAR EVENTS i
o RECOMMENDATIONS IMPLEMENTED BY DECEMBER 31, 1989 DIFFICULTY IN INFORMATION RETRIEVAL RESOLUTION:
o COMPLETED A RECONSTITUTION OF THE J
NCR DATABASE 3434 NCR'S SEEKABLE WITH SORT FUNCTIONS
SUMMARY
INFORMATION AVAILABLE UPON SCREEN RETRIEVAL i
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ROOT CAUSE ANALYSIS FREQUENTLY INEFFECTIVE
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O COMPLETED INITIAL r, IMPLEMENTED ONCOING RCA TRAINING i
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O HAVE PLACED ADDITIONAL EMPHASIS ON
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RCA DETERMINATIONS I.
o COMPLETED AN ENGINEERING h
DEPARTMENT INSTRUCTION TC L
STANDARDIZE OOCUMENT SEARCH L
CRITERIA f
o ADDITIONAL RCA IMPROVEMENTS l
ESTABLISH THRESHOLD FOR DETAtLED RCA: SCRAM, FORCED OUTAGE, POWER REDUCTION, SAFE SHUTDOWN i,
RCA CUIDELINE MULTlDISCIPLINED RCA COMMITTEE o
ADDITIONAL IMPROVEMENTS IMPLEMENTED BY DECEMBER 31, 1989 COMPLETION OF CORRECTIVE ACTION RESOLUTION:
i REVISED 0.5.1, "NONCONFORMANCE AND i
o CORRECTIVE ACTIONS," TO IMPROVE i
ADMINISTRATIVE CONTROL OF CORRECTIVE ACTION TRACKING AND IMPLEMENTATION CLEARLY IDENTIFIED l
ASSIGNED
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i RECOMMENDED LICENSEE ACTIONS I.
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o-IMPROVEMENT OF THE CORRECTIVE ACTIONS PROGRAM WITH EMPHASIS ON ROOT CAUSE DETERM! NATION iz-I COMPLETED A MAJOR ADMINISTRATIVE CHANGE TO THE CORRECTIVE ACTION PROGRAM COMPLETED 3RD PARTY REVIEW OF RCA l
PROGRAM WITH RECOMMENDATIONS IV.PLEMENTED BY DECEMBER 31, 1989 COMPLETED RECONS 7f TL* TION OF THE NCR DATABASE i
IMPLEMENT RCA IMPROVEMENTS BY DECEMBER 31, 1989 i
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l
FFBRUARY 1,1988 - APRIL 15,1989 t
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RECOMMENDATION:
!MPROVE. REVIEW OF INDUSTRY EVENTS AND IMPLEMENTATION OF LESSONS LEARNED.
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CHRIS R. MOELLER TECHNICAL STAFF SUPERVISOR - CNS a
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RECOMMENDATION: IMPROVE REVIEW OF INDUSTRY EVENTS AND
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lMPLEMENTATION OF LESSONS LEARNED.
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CONCERNS:
A yearly review of Industry events and reports !s performed; however, implementation of recommendations was not evident.
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bbe The 1987 review identified three *ecommendMicns; however, there l
was, ne followup of thee recommendaticns in Pie 1988 review.
i Nonconformance Reports are reviewed for adequacy of root cause determination; however, in some instances this review was performed by the same individual who performed the initial root cause determination.
There are over 200 Nonconformance Reports open at CNS awaiting completion of corrective action or verification of completion.
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A yearly review of Industry events and reports is performe y-.
however.fimplementation of recommendstions was not evident, y
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ACTION:
First review completed in December of 1987. Three recommeridations identified.- Recommendations dispositioned as documented in April 28,1988, memo.
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ACTION REMAINING TO BE IMPLEMENTED:
None.
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CONCERN:
The 1987 review' identified three recommendations, however, there was no followup of these recommendations in the 1988 s
review.
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1988 review amended to include followup of 1987
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4 r(commendations.
2.
Procedure was reviced to require review of previous recommendatioist.
~ ACTION REMAINING TO O'2 (MPl.EMENTED:
None.
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. CONCERN:
Nonconformance Reports (NCRs) are reviewed for adequacy of root cause determination: however, in some instances this review was performed by the same individual who performed the initial root cause determination.
ACTION:
1.
Concern evaluated for frequency and significance.
Frequency - Potential only for reportable NCRs (37 of 232 NCRs for 1988).
Significance - SORC reviews all reportable NCRs for root cause and corrective actions. Technical Staff review an administrative function, i
2.
The Technical Staff se.sluwers requested to avoid reviewing reportable NCRs they prtpared.
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l ACTION REMAININO TO DE IMPLEMENTED:
Nene.
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- ENH ANCEMENTS:
1.
Procedure being revised to add both Senior Managers to the closeout review of NCRs.
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There are'over 200.Nonconformance Reports open at CNS f
awaiting _ completion of corrective action or verification of completion..
AC Nonconformance program enhanced to include accountability and
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~ improved action tracking.
Down from 200 to approximately 115.
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= ACTION REMAINING TO IMPLEMENTED:
None.
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