ML20046D379
| ML20046D379 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/11/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NSD930977, NUDOCS 9308190069 | |
| Download: ML20046D379 (10) | |
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GENERAL OFFICE CD fP)
P O. BOX 493. COLUMBUS. NE BRASKA 68602@99 Ils
+{hN3a's Nebraska Public Power D. tnct TELEPHONE (402) 564-8561 v:
is FAX (40M SG5551 C'
NSD930977 August 11, 1993 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Centlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP)
Report (Inspection Re. port 50-928/93-99)
On July 12, 1993, Nebraska Public Power District (NPPD) management perronnel met with NRC management to review the results of the SALP report for Cooper Nuclear Station (CNS) for the period January 19, 1992 through April 24, 1993.
The purpose of this letter is to provide comments on the SALP report in addition to those made at the public SALP meeting.
NPPD wishes in emphasize its commitment to the continued safe operation of CNj.
As indicated by NPPD management at the public SALP meeting, the District will be focusing intensely on the issues contained in the SALP report to improve *.he overall performance of Cooper Nuclear Station.
The District will commit the resources and management attention necessary to effect the necessary improvements in the District's nuclear program.
NPPD has analyzed the licensee recommendations identified in the SALP report and the attachment addresses the recommendations made by the NRC in each appropriate functional area.
As stated during the SALP meeting, many corrective measures have been taken or are in progress to address the concerns expressed in the SALP report.
The District appreciates the feedback provided by the SALP process and is committed to significant improvement in the performance of CNS.
Sine rel,
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Horn Nu r Power Group Manager
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'NSD930977l August 11, 1993
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Regional Administrator USNRC Region IV NRC Resident Inspector Cooper Nuclear Station
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Attachment-Page 1 of 8 i
SALP RECOMMENDATIONS AND RESPONSES i
July 1993 i
A.
Plant Operations NRC Recommendation Licensee management needs to take appropriate measures to assure that the j
long-term issue of operator communications during nonroutine ope. rating activities has been included in the training process for all operators.
t The licensee should implement an effective process for the evaluation of r
deficient conditions that impact the safe operation of the facility.
NPPD Response Operations management has exerted considerable effort towards irprovemont of operator communications as described in the quarterly status repo rts of.
the 1992 SALP Action Plan.
The most recent SALP. report appropriately described this issue as an " ongoing challenge".
In an effort to enlist l
the support of those affected, Operations management will meet with the-supervision from each operating crew to discuss communication inadequacies and to solicit their input for implementing further improvements. _ Topics currently under consideration are objective grading of communications during training, incentives for high performance, methods for utilization of video taping to improve communications, the retention of training principles such that lessons learned are taken back into the plant Control Room and increased overview by management.
The Operability Determination process will be reviewed and revised, as necessary, to enhance Shift Supervisor review of Operability Determinations and Evaluations. This enhancement will further the review process to promote technical adequacy and effectiveness.
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i NSD930977 Attachment Page 2 of 8 B.
Radiological Controls NRC Recommendation The licensee needs to implement measures to assure that the facility. staff is more aggressive in the pursuit of issues which are to be documented in the radiological safety incident report process by site procedures.
NPPD Response To upgrade the radiological problem resolution process, the Corrective 7
Action Program will be revised to clearly describe occurrences which meet the established initiation criteria for a Radiological Safety Incident
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Report (RSIR). These criteria will be established such that radiological incidents which demonstrate a weakness in the CNS Radiation Protection Program will receive the necessary station management attention and involvement to ensure timely, results-oriented corrective action.
To address less significant radiological problems, new thresholds, comparable to the those currently - established in the lower threshold Corrective Action Program, - will be developed.
These thresholds will j
address occurrences indicative of undesirable performance, with the degree of radiological safety significance lower than that established by the RSIR.
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Trending of radiological problems will be developed to provide a mechanism by which Station Management is kept informed of the' Radiation Protection Program performance.
The procedure changes necessary to upgrade the Corrective Action Program
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relative to radiological problem resolution will be developed and i
implemented by January 1994 i
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NSD930977 Attachment I
Page 3 of 8 C.
Maintenance / Surveillance
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NRC Recomam ndation The licensee should review the scope and depth of maintenance / surveillance activities to make sure that the maintenance and surveillance programs for i
safety-related equipment are adequate to assure that the equipment can and will continue to perform its safety functions. The licensee should also increase the emphasis on oversight by plant management and systems engineering to provide an increased level of technical support to the maintenance and surveillance activities at the plant. Management should provide additional emphasis on generation of thorough and detailed maintenance and surveillance procedures, and on the need for maintenance / surveillance personnel to carefully follow the procedures.
NPPD Response i
Maintenance activities and programs for all safety-related systems, f
structures, or components will be reviewed in conjunction with Maintenance f
Rule implementation.
Preventive Maintenance activities and maintenance l
procedures will be thoroughly reviewed as a part of this process and will be revised as necessary to ensure accuracy..
Maintenance craft training will continue to stress the necessary requirements for procedural compliance and attention to detail.
Maintenance Management and Supervisors will monitor performance in this area through field c",servation in accordance with Maintenance Procedure 7.0.4, Conduct of Maintenance.
The SALP analysis for the Maintenance / Surveillance area noted that
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corrective actions had been initiated for several issues identified at the end of the SALP period which will be continued during the next period.
Some of the specific programs which will receive additional evaluation
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include pressure isolation valve and check valve testing, local leak rate testing, and inservice inspection and testing.
In addition, the verification of the adequacy of surveillance procedures has been included in the Design Basis Reconstitution Program. More emphasis is being placed on system engineer involvement in overall plant problems from initial identification through the timely, complete achievement of results.
It will be stressed with Maintenance and Operations personnel to utilize the Engineering staff when problems first arise to enhance their resolution.
As noted in the Engineering / Technical Support response, system engineer involvement led to the resolution of a number of longstanding and emergent problems during the refueling outage. Engineering is also reviewing their current programs to ensure there is better utilization of their resources.
These actions will ensure better responsiveness and overview of plant activities.
In addition, attention to the above activities and to compliance with all maintenance and surveillance procedures will be emphasized by Management.
j NSD930977
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Attachment i
Page 4 of 8 D.
Emerrency Preparedness l
NRC Recommendation Licensee needs to take actions to assure that the recurring issues in offsite notification, emergency assessments, and decision making have been corrected.
i NPPD Response The District has installed a new " hotline" telephone system to remedy the i
recurring problems with late offsite notification.
The new system is independent of the local telephone switching channels and will therefore i
be available even if local telephone usage is heavy.
The system was successfully demonstrated during the initial notification of the recent July 24, 1993 Notification of Unusual Event brought about by local area flooding around the plant. The new system completed notification to all applicable agencies within eight minutes of its initiation, well within the 15 minute criteria. Additionally, revisions have been made to plant procedures to ensure adequate communication takes place between the Station Operations Review Committee and the Shift Supervisor on matters i
which may involve an event with an emergency classification.
This upgraded coordination has been demonstrated to be effective on three separate occasions in ensuring the timely declaration and notification of l
an event at Cooper Nuclear Station.
t A change to the Emergency Response Organization (ERO) has been implemented to address the weakness noted in the area of emergency assessment. This change now has the Plant Manager remaining in the Technical Support Center (TSC) in the role as the Emergency Operations Director,. rather than i
physically moving out to the Emergency Operating Facility. By remaining in the TSC, the Plant Manager will enhance the plant technical support and emergency assessment activities so that the facility can maintain a continuity of planning and implementation of the necessary support
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activities. In addition, ERO position specific training covering Accident Management Techniques was conducted in March, 1993 to enhance personnel L
knowledge and consideration of emergency assessment.
Aspects of this training will be incorporated into the ongoing EP training and assessment f
process.
The skills acquired from this training were effectively demonstrated during a June 15, 1993 drill.
In the area of decision making, training has been conducted for " low threshold" core damage events f
where the indicated plant parameter are close to the threshold levels for declaring a General Emergency.
Particular emphasis has been placed on degraded core symptoms and indicators for the potential loss of fission j
product barriers. These " low threshold" core damage scenarios have been included into the training program for future training and drills.
In addition, practices at other nuclear facilities in these areas are l
observed on a periodic bases by District personnel and evaluated for incorporation into the District's program as appropriate.
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NSD930977 Attachment j
Page 5 of 8
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E.
Security-NRC Recommendation j
None.
NPPD Response Security will continue to receive strong management support with emphasis -
on program improvements.
To enhance personnel readiness, response.
I contingency training and force-on-force exercises will be a priority.
Additionally, training aids will continue to be assessed and upgraded, accordingly. To enhance security system readiness and response, a video capture system will bo installed.
Once implemented, these enhancements will be assessed to assure the ongoing effectiveness of the Security ~
program.
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I NSD930977 Attachment-Page 6 of 8 F.
Encineerinr1 Technical Support NRC Recommendation The licensee needs to resolve plant problems by correcting the root cause, with the objective of closing the issue with finality, rather than by quick-fix approach to mitigate the immediate symptoms.
.The using a licensee should put more thoroughness, formality, and attention to careful documentation into the process. The licensee should also give management oversight au:/or system engineering function more emphasis, with more responsibility and authority for reviewing all aspects of a problem.
NPPD Response Actions have been initiated to strengthen the Engineering / Technical Support staff in order to provide more effective support of plant operation.
Increased emphasis is being placed on system engineer involvement in plant problems from the initial identification through the timely, conclusive achievement of results. Multi-disciplinary or multi-'
system tasks assigned to the engineering staff are now being evaluated and resolved through the use of an engineering department instruction to ensure comprehensive reviews and corrective actions are performed.. Job performance guidelines for system engineers will also be reviewed and clarified as appropriate to ensure management expectations are clearly l
defined.
To promote the identification and correction of problems which may constitute a nuclear safety concern, Management expectations stressing the need for a questioning attitude have been effectively communicated to Engineering personnel.
This has resulted in the resolution of several longstanding problems and numerous emergent problems during the recently completed refueling outage.
This same attitude is being stressed to eliminate repeat equipment failures by ensuring engineering evaluations are performed in a rigorous formal manner relying on confirmation of results.
In addition, management is emphasizing the identification and resolution of plant problems as a positive aspect of their jobs.
These changes will continue to be reinforced and supported to ensure that the practices become deeply ingrained in the engineering culture.
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Various policies and procedures are being evaluated to increase the efficiency and timeliness in which problems are resolved. In addition, a review has identified the need for streamlining some programmatic processes, and the redistribution of others, in order to better utilize the CNS engineering resources.
Finally, managerial oversight of system engineer activities is being increased to ensure that appropriate levels j
of responsibility and authority are assigned for resolving all aspects of plant problems.
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q NSD930977 Attachment Page 7 of 8 i
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Safety Assessment /Ouality Verification i
i NRC Recommendation i
Licensee management needs to perform a critical assessment of their l
corrective action processes in light of the problems identified by the NRC i
and correct the process to assure that the process is meeting licensee and NRC expectations.
4 NPPD Response The District has performed a critical assessment of the Corrective Action Program through multiple approaches and means.
These elements of our assessment are as follows:
1)
A Corrective Action Program Overview Group (CAPOG) was. found in -
April,1993 to ensure that problems related to nuclear safety were:
a)
Promptly identified i
b)
Properly evaluated regarding their significance c)
Effectively communicated to appropriate personnel f
I d)
Aggressively resolved with rigor commensurate with their safety significance.
I The CAPOG is caposed of three senior personnel dedicated full time to this effort and reports to the site manager.
Assessment of CAPOG's l
activities by Quality Assurance and 'an outside expert have concluded that CAPOG was effective and was helping communicate managements' expectations i
to plant personnel of a safety first and fix it right the first time culture.
2)
The existing Corrective Action Program as a whole was recently evaluated by a Corrective Action Program Self Assessment Group (CAPSAG). The scope of its review was to evaluate:
a)
Managements' effectiveness in directing, l
supporting and monitoring the Corrective Action 3
Program b)
Corrective Action Program content, method and implementation l
c)
Corrective Action Program overall effectiveness
NSD930977 Attachment
-Page 8 of 8 3)
An investigative team was formed in July, 1993 to perform an independent assessment of enforcement issues identified in IRC Inspection Report 93-17.
One of the objectives of this six member team was to determine the adequacy of the proposed corrective actions to the identified issues and to recommend additional actions to prevent recurrence.
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A performance assessment project was performed in late 1992 by an outside agency at the request of senior NPG management to:
a) identify root causes of the lack of uniform performance i
by District personnel b) identify changes needed to raise levels of performance up to managements' expectations c) provide recommendations to effect these changes Information and conclusions of the above group's assessments of the Corrective Action Program have been taken and evaluated by NPG senior management. It has been determined that the program must be improved by:
1)
Improving the process by making it more stream lined i
2)
Clarification and enforcement of ownership and accountability 3)
Improve communications at all levels to ensure all personnel get the same message 4)
Establish program performance monitoring including indicators.
5)
Increased management oversight of the corrective action process.
The District believes the above efforts and the future program improvements will address the District's concerns with the Corrective Action Program.
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