ML20056G744
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| ML20056G744 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/27/1993 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9309070112 | |
| Download: ML20056G744 (16) | |
See also: IR 05000298/1993099
Text
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Docket: 50-298
License: DPR-46
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Nebraska Public Power District
ATTN: Guy R. Horn, Vice President, Nuclear l
P.O. Box 98 i
Brownville,_ Nebraska 68321 ;
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SUBJECT: . FINAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT
This forwards the final SALP report (50-298/93-99) for the Cooper Nuclear
Station for the period of January 19, 1992, through April 24, 1993. This
'
final SALP Report includes: i
1. The cover letter for the initial SALP report (no revisions to the
initial SALP report were made).
2. A summary of our July.12, 1993, meeting at the Cooper Nuclear Station
security building auditorium'in Brownville, Nebraska. j
Your August 11,.1993, response to the initial SALP report. l;
3.
l
We have reviewed your letter dated August 11, 1993, in response to the NRC !
recommendations in each of the SALP functional areas. It was noted that your !
response has identified specific-actions to improve performance in each of the l
SALP. functional areas. -We will review your progress to achieve these !
improvements in inspection efforts during this SALP period. l
l ,
The next SALP period for Cooper Nuclear Station is scheduled to last
approximately 18 months, from April 25, 1993, to October 22, 1994. As
identified in our letter dated August II,1993, from Mr. A. B. Beach,
. Director, Division of Reactor Projects, to Mr. G. R. Horn, Vice President, L Nuclear, the revised SALP program will be utilized.
Sincerely,
030014 y gh[
F egional Administrator ;
Enclosures:
:1. Cover letter for the initial SALP report
2. NRC Meeting Summary
3. Nebraska Public Power District response to the initial SALP report pD1
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9309070112 93D827
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NRC FILE PRTER COPY
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Nebraska Public Power District l
ATTN: G. D. Watson, General Counsel *
P.O. Box 499 i
Columbus, Nebraska 68602-0499 i
Cooper Nuclear Station. .
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ATTN- John M. Meacham, Site Manager -
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P.O. Box 98~ l
Brownville, Nebraska 68321 :
l' l Nebraska Department of- Environmental !
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Control i'
' ATTN: Randolph Wood, Director
P.O. Box 98922
Lincoln, Nebraska 68509-8922 i
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Nemaha County Board of Commissioners !
ATTN: Richard Moody, Chairman !
Nemaha County Courtbr se. !
1824 N Street- l
' Auburn, Nebraska 68305 !
Nctraska Department of Health !
ATTN: Harold Borchert, Director .
Division of Radiological Health - i
301 Centennial Mall, South l
P.O. Box 95007 i
Lincoln, Nebraska 68509-5007 i
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Kansas Radiation Control Program Director '
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Commissioner Rogers (MS: 16-G-15) G. F. Sanborn, E0
C. J. Gordon 0:DRP
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Commissioner..de Planque (MS: 16-G-15) L. J. Callan, D:DRSS l
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Commissioner Rogers (MS: 16-G-15) G. F. Sanborn, E0
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Commissioner Remick (MS: 16-G-15) RRIs at all sites
Commissioner de Planque (MS: 16-G-15) L. J. Callan, D:DRSS
J. M. Taylor, EDO (MS: 17-G-21) D. D. Chamberlain, DRSS
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ENCLOSURE 1 l
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Docket: 50-298 i
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Licenses DPR-46
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; Nebraska Public' Power District j
ATTN: Guy R.' Horn, Nuclear' Power j
Group Manageri ;
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-P.O. Box 499-
. Columbus Nebraska 168602-0499"
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SUBJECT: INITIAL: SYSTEMATIC ASSESSMENT 0F' LICENSEE PERFORMANCE (SALP) REPORT f
This forwards'therinitial SALP. report (50-298/93-99) for. the Cooper Nuclear
. Station. The SALP Board met on May 20 and June 15, 1993, to evaluate the !
licensee's performance for thefperiod January 19, 1992,. through April 24, I
1993. The performance analyses and:resulting evaluations are documented in
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the-enclosed initial SALP report.
In :accordance. with NRC policy, I Lhave' reviewed the SALP Board's- assessment and '
. concur'with'their ratings, as discussed below:
Overall,11icensee ' performance declined in several functional' areas from the
Lprevious SALP evaluation. A large' number of equipment problems occurred !
: during.the latter part of thisl appraisal period that' were' caused, in part, by
the. failure'of licensee employees to. aggressively pursue the root cause of
-potentially~significant equipment problems and to assume' effective ownership '
of. systems:and components. The problems were also caused by the willingness -
offlicenseel personnel to live with problems rather'than thoroughly evaluate
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. degraded or potentially degraded equipment issues. . The' Cooper Nuclear Station
l staff appears to be satisfied with. working around these. problems and, as a
l- result, the licensee's problem resolution process and corrective action
systems have been weak. Many of these equipment' problems were long-standing,
' and the ' f ailure to self-identify _ and correct- the problems are viewed as
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demonstrated fundamental weaknesses- in the oversight and self-assessment
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functions. These concerns were most evident in the a_reas of
Maintenance / Surveillance 'and Safety Assessment / Quality Verification and, as a
result,.these areas were assigned-a rating'of Category 3.
In Engineering / Technical: Support.Lsignificant weaknesses were observed in
.p'roblem resolution.by the site engineering group. The board was concerned
.with the' examples .of insufficient rigor applied to the evaluation and
-resolution of'1dentified problems. The evaluations. relied heavily on verbal
.information andithere was. lack of.. formality-in the approach to the resolution
:of these problems.which-contributed to escalated enforcement actions. The
board; assigned'a rating of Category l2 because of the performance of the
corporate engineering. group'and the improvements in operations training.
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Nebraska Public Power District -2-
Performance in the functional area of Operations was mixed and assigned a
rating of Category 2. Routine operations remained strong, but there was a
lack of a questioning attitude on the part of the operating staff for some
engineering operability determinations. This lack of a questioning attitude !
may have contributed to some of the plant problems identified during this ;
period. The relationship between the operations and training staffs has <
improved but requires some additional attention. '
3
In Radiological Controls, performance has improved. The radiological controls
staff has made major strides in improving the overall prognm. The board was l
concerned, however, with the apparent lack of aggressiveness in identifying
radiological performance weaknesses. Nevertheless, overall performance was '
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assigned a rating of Category 2 and was assigned an improving trend. !
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Recurring problems in the areas of offsite notification, emergency assessment,
and decisionmaking tended to offset the improvements noted in the area of
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Emergency Preparedness. The failures to follow up on previously identified :
findings and tht: additional violations indicated a need for increased i
management attention. This area was assigned a rating of Category 2 with a i
declining trend. ;
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The area of Security continues to be a strength.and was assigned a rating of
Category 1.
On the basis of the SALP Board's assessment, the length of the SALP period
will be'approximately 15 months. Accordingly, the next SALP period will be
from April 25, 1993, to July 30, 1994
A management meeting has been scheduled with you and your staff to review the 4
results of the initial SALP report. The meeting will be open to the public j
and held at the Cooper Nuclear Station security building auditorium on July 9,
1993, at 10 a.m. Within 20 days of this management meeting, you may provide
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comments on and amplification of, as appropriate, other aspects of the initial :
SALP report.
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Your written comments, a summary of our meeting, and the results of my [
consideration of your comments will be issued as an appendix to the enclosed i
initial SALP report and will constitute the final SALP report. 1
Sincerely,
(
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ames b.
L. Milhoan
Regional Administrator
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Enclosure 2
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\ llc _ EAR REGL _ATORY
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SYS- E!V K-'C ASSESSMEN--
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i i t i 1 e L COOPER NUCLEAR STATION 4 l . , i ! I d )
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4 4 h 1 f f i 4 i
JANUARY 19,1992
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APRIL 24,1993
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AGENDA
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INTRODUCTIONS NRC
NPPD
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OPENING REMARKS / JAMES L. MILHOAN !
PERFORMANCE OVERVIEW
FUNCTIONAL AREA DISCUSSION A. BILL BEACH
COMMENTS AND/OR QUESTIONS NPPD
CONCLUDE MEETING
COMMENTS AND/OR QUESTIONS PUBLIC/ MEDIA
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OVERVIEW OF PERFORMANCE
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; * DECLINING PERFORMANCE
- * FAILURE TO SELF-IDENTIFY PROBLEMS
* WEAK PROBLEM RESOLUTION
. l o A LACK OF A QUESTIONING ATTITUDE
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o WORK AROUND PROBLEMS
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o WEAK ROOT CAUSE ANALYSIS
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PLANT OPERATIONS
CATEGORY 2
PERFORMANCE MIXED
* WEAKNESSES DESCRIBED IN PREVIOUS SALP
RECEIVED MANAGEMENT ATTENTION
* MANAGEMENT ATTENTION EVIDENT IN ROUTINE
OPERATIONS
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* HOUSEKEEPING GOOD
* LACK OF QUESTIONING ATTITUDE - OPERABILITY
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DETERMINATIONS
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- - - ._ . - - - - - - _ _ - - - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ - - _ - . _ _ _ _ . _ _ -
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MAINTENANCE / SURVEILLANCE
CATEGORY 3
SIGNIFICANT DECLINE IN PERFORMANCE
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e WEAKNESSES IN TESTING AND MAINTENANCE OF
EQUIPMENT
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- o REACTOR BUILDING
! o SERVICE WATER SYSTEM i o REACTOR COOLANT PRESSURE ISOLATION l VALVES ! o CONTAINMENT ISOLATION VALVES l o STATION BATTERIES
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- _ _ - _ - - - _ _ - _ - - - - - _ _ - _ - - _ _ - _ - _ - _ - _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ .
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SECURITY
CATEGORY 1 1
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STRONG PERFORMANCE
. ! e PERFORMANCE EXCELLENT I ! .
* PROGRAMS EFFECTIVELY MANAGED -
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SAFETY ASSESSMENT /
QUALITY VERIFICATION
CATEGORY 3
FUNDAMENTAL WEAKNESSES IN CORRECTIVE ACTION
PROCESSES AND SELF-ASSESSMENT
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e INEFFECTIVE PROBLEM RESOLUTION
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e OVERSIGHT AND SELF-ASSESSMENTS DID NOT
IDENTIFY WEAK CORRECTIVE ACTION PROCESSES
i l * INITIATIVES TO IMPROVE CORRECTIVE ACTIONS
IMPLEMENTED
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PLANT OPERATIONS
CATEGORY 2
PERFORMANCE MIXED
e WEAKNESSES DESCRISED IN PREVIOUS SALP
RECEIVED MANAGEMENT ATTENTION
* MANAGEMENT ATTENTION EVIDENT IN ROUTINE
OPERATIONS
* HOUSEKEEPING GOOD
* LACK OF QUESTIONING ATTITUDE - OPERABILITY
DETERMINATIONS
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- RADIOLOGICAL CONTROLS
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CATEGORY 2
IMPROVING PERFORMANCE
* STRONG MANAGEMENT SUPPORT FOR ALARA
PROGRAM
e EFFECTIVE EXTERNAL AND INTERNAL EXPOSURE
CONTROLS
* NOT AGGRESSIVE IN IDENTIFYING PERFORMANCE
WEAKNESSES
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MAINTENANCE / SURVEILLANCE
C ATEGORY: 3
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- SIGNIFICANT DECLINE IN PERFORMANCE
l ! e WEAKNESSES IN TESTING AND MAINTENANCE OF
a
EQUIPMENT
i ! o REACTOR BUILDING l
o SERVICE WATER SYSTEM
! o REACTOR COOLANT PRESSURE ISOLATION ! VALVES '
o CONTAINMENT ISOLATION VALVES
l o STATION BATTERIES l ! ! !
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EMERGENCY PREPAREDNESS
CATEGORY 2
DECLINING PERFORMANCE
* IMPROVEMENTS IN AREAS NOTED IN PREVIOUS
SALP
* RECURRING PROBLEMS NOTED IN OFF SITE
NOTIFICATIONS, EMERGENCY ASSESSMENTS, AND
DECISION MAKING
* INCREASED MANAGEMENT ATTENTION NEEDED
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SECURITY
CATEGORY 1
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STRONG PERFORMANCE
e PERFORMANCE EXCELLENT
e PROGRAMS EFFECTIVELY MANAGED
- _ _ . _ - . _ . _ _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _ - _ - _ _ - .- - - - - - - - - . . . , - ~ - - - , - - - - - . - ~ , . - , . -+-..., ..---..-...--.- - -, .. ..- _ _ _ _ - - ._ _
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ENGINEERING / TECHNICAL SUPPORT
CATEGORY 2
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ENGINEERING PERFORMANCE MIXED
* MODIFICATION PROCESS EFFECTIVE
* SIGNIFICANT WEAKNESSES IN PROBLEM
RESOLUTION
3
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SAFETY ASSESSMENT /
QUALITY VERIFICATION
CATEGORY 3
FUNDAMENTAL WEAKNESSES IN CORRECTIVE ACTION
PROCESSES AND SELF-ASSESSMENT
* INEFFECTIVE PROBLEM RESOLUTION
* OVERSIGHT AND SELF-ASSESSMENTS DID NOT
IDENTIFY WEAK CORRECTIVE ACTION PROCESSES
e INITIATIVES TO IMPROVE CORRECTIVE ACTIONS
IMPLEMENTED
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COOPER. NUCLEAR STATION
OVERALL PERFORMANCE SUMMARY
RATING LAST RATING THIS
PERIOD PERIOD
FUNCTIONAL AREA
7/16/90-1/18/92 1/19/92- 4/24/93
2 2
PLANT OPERATIONS 2'
2
RADIOLOGICAL CONTROLS
1 3
MAINTENANCE /SURVElLLANCE
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2 2"
EMERGENCY PREPAREDNESS
1 1
SECURITY
2 2
ENGINEERING / TECHNICAL SUPPORT
2 3
SAFETY ASSESSMENT / QUALITY VERIFICATION
* IMPROVING TREND
* * DECLINING TREND
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ENCLOSURE 3
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GENER AL OF FfCE
=~ ' P O BCx 899 COLUMBUS NEBRASKA 686024499
- Nebraska Public Power District ~'% MTATf"' __
NSD930977
Auguat 11. 1993
U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555
Gentlemen:
Subject: Sveramarie Aasm _= =* m e of 1.i cens ee Performance (SALP) Report
(inspection Report 50-928/93-vy)
On July 12, 1993, Nebraska Public Power District (NPPD) management personnel 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 neering.
NPPD wishes in emphasize its commitment to the continued safe operation of CNS.
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 the
overall performance of Cooper Nuclear Station. The District will com:mit the
resources and management attention necessary to effect the necessary improvements
in the District's nuclear program.
NPPD has analyzed the licensee recom:nencations 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 perforznance of CNS.
Sine rel ,
C. .
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N r Power Croup Manager g
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NSD930977
August 11. 1993
Page 2
cc: Regional Administrator
USNRC Region IV
NRC Resident Inspector
Cooper Nuclear Station
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NSD9309',7 !
Attachement f
Page 1 of 8 !
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SALP RECOMMENDATIONS AND RESPONSES
July 1993 ,
A. Plant Onorations ,
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HEC Race - ndation i
Licensee management needs to take appropriate measures to assure that the j '
long-term issue of operator communications . during nonroutine operating
activities has been included in the training process for all operators. j
The licenses should implement an effective process for-the evaluation of ;
deficient conditions that impact the safe operation of the facility, j
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NFPD Response
Operations management has exerted considerable effort towards improvement !
of operator communications as described in the quarterly status reports of j
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the 1992 SALP Action Plan. The most recent SALP report appropriately
In an effort to enlist l
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described this issue as an " ongoing challenge *.
the support of those affected, Operations management will meet with the l
- supervision from each operating crew to discuss communication inadequacies l
and to solicit their input fer implement % further improvements. Topics !
currently under consideration are objecciva grading of casesunications [
during training, incenti_ves for high performance, methods for utilization j
of video taping to improve communications, the retention of training l
principles such that lessons learned are taken back into the plant Control l
Room and increased overview by .ansgsment. l
The Operability Determination process will be reviewed and revised, as ,
necessary, to enhance Shift Supervisor review of Operability i
Determinations and Evaluations. This- enhancement will further the review
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process to promote technical' adequacy and effectiveness.
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NSD930977
Attachment
Page 2 of 8 ,
B. - h diolonical Controls
NRC Reec--- dation
The licensee needs to implement measures to assure that the facility staff
is imore 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
Action Program will be revised to clearly describe occurrences which meet
the established initiation criteria for a Radiological Safety Incident
Report (RSIR) . These criteria vill 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. i
To address less significant radiological problems, new thresholds, ,
comparable to the those currently established in the lower threshold l
Corrective Action Program, will be developed. These thresholds will ,
address occurrence.s indicative of undesirable performance, with the degree 1
of radiological safety significance lower than that established by the l
RSIR.
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
relative to radiological problem resolution will be developed and
implemented by January 1994
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NSD930977 l
Attachment )
Page 3 of 8 )
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C. Maintenance /Surve111ance j
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MRC Racommandation
The licensee. should review the scope and depth of maintenance / surveillance
activities' to make sure that the maintenance and surveillance programs for
- safety-related equipment are adequate to assure chat the equipment can and
will, continue to perform its safety functions. The licenses should also
increase ;the emphasis on oversight by plant w=mgement and systems
engineering to . provide an increased level of technical support to the
maime====ce and surveillance' activities at the plant. Management should
provide additional emphasis . on generation of thorough and detailed
ma?ntenance .and surveillance procedures, and on the need for
mainte== nee / surveillance personnel to carefully. follow the procedures.
NFFD Rappense
Mainte===ce activities and programs' for all safety-related systems,
structures, or components will be reviewed in conjunction with Maintenance
Rule implementation. Preventive Maintenance activities and maintenance
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
observation in accordance with Maintenance Procedure 7.0.4, Conduct of
Maintenance.
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Tkw SALF analysis 'for the . Maintenance / Surveillance area noted that
corrective actions had been initi.ated 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 overdi plant problems from initial I
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identification through the tisaly, complete achievement of results. It
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will be ' stressed with Maintensace and operations personnel to utilise the
Engineering staff when problems first arise to enhance their resolution.
As noted in the Engi.neering/Jachnical Support response, system engineer
involvement led to the resolution of a number of longstanding and emergent
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problems during the refueling outage. Engineering is also reviewing their
current programs to ensure there is better utilization of their resources. 1
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. l
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NSD930977
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Page 4 of B f
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.D. Emergency Prpoaredness
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i 1RC Racemmenda): ion
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Licensee nmeds to take actions to assure that the recurring issues in
f' ' offsite notification, amer 5ency assessments, and decision making have been l
corrected..
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MFFD Raanonse
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The District has installed a new ' hotline *. telephone system to remedy the
recurring problems with late offsite notification. The new system is >
independent of the. local telephone switching. channels and.will therefore
, be available even if . local telephone usage is heavy. The system was
successfully demonstrated during the initial notification of the recent ,
L : July 24, 1993 Notification of Unusual Event brought about by local area ,
flooding around the plant. The new system completed notification to all l
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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 cosmiunication takes place between the I
Station Operations Review Committee and the Shift Supervisor on matters
which may .. involve an event with an emergency classification. This !
upgraded coordination has been demonstrated to be effective on three l
separate occasions in ensuring the timely declaration and notification of !
an event at' Cooper Nuclear Station. [
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A change to the Emergency Response Organization (ERO) has been implemented
to address the wa=1 mass noted in the area of emergency assessment. This [
change now has the Plant Manager remaining in the Technical Support Center !
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(TSC) in the role as the Emergency Operations Director, rather than
physically moving out to the Emergency Operating Facility. By remaining
in the TSC, the Plant Manager will enhance the plant technical support and ,
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emergency assessment activities so that the facility can maintain a
continuity of planning and implementation of the necessary support i
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activities. . In addition, ERO position specific training covering Accident [
Nanagement Techniques was conducted in March,1993 to enhance personnel
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knowledge and 1 consideration of emergency ' assesamant. Aspects of this
training will-be incorporated into the ongoing EP training and assessment I
process. .The skills acquired from this training were effectively ;
demonstrated during a June 15, 1993 drill. In the area of decision !
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making,' training has been conducted for " low threshold * core damage events
'where the indicated plant parameter are close to the threshold levels for
. declaring a General Emergency. Particular emphasis han been placed on l
degraded core symptoms and indicators for the potential loss of fission !
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product barriers. These ' low threshold" core damage scenarios have been In
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included into the . training program for future training and drills. l
addition, practices at other nuclear facilities .in these areas are ,
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
Page 5 of 8 !
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E. Security
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NRC Kecoman.ndation l
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None. I
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NFFD Resnonse I
security will continue to receive strong management support with emphasis
on program improvements. To enhance personnel readiness, response
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 be installed. Once implemented, these enhancements
will be assessed to assure the ongoing effectiveness of the Security
program.
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NSD930977
Attachment
Page 6 cf 8
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F. heinserine/ Technical Supeort
HE9 EAAREupendation
The licensee needs to resolve plant problems by correcting the root cause,
with the objective of closing the issue with finality, rather than by
using a quick-fix approach to mitigate the insmediate sympcoma. The
licensee should put more thoroughness. formality, and attention to careful
documentation into the process. The licensee should also give management
oversight and/or system engineering function more emphasis, with more
responsibility and authority for reviewing all aspects of a problem.
NPPD Resnonse
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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 casks 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
defined.
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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 fs' 5res by ensuring engineering evaluations
are performed in a rigorous Lnaal 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.
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 activitiss is being increased to ensure that appropriate levels
of roeponsibility and authority are assigned for resolving all aspects of
piant probisms.
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NSD930977
Attachment
Page 7 of 8
C. Safety Assasemarie/Ouality Verification
NRC Recommendation
Licenses management needs to perform a critical assessment of their
corrective action processes in light of the problems identified by the NRC
and correct the process to assure that the process is meeting licensee and
NRC expectations.
NPFD Rasnonse
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
b) Properly evaluated regarding their significance
c) Effectively cwmicated to appropriate personnel
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d) Aggressively resolved with rigor commensurate with their
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safety significance.
The CAPOG is composed of three senior personnel dedicated full time to
this effort and reports to the site manager. Assessment of CAPOG's
activities by Quality Assurance and an outside expert have concluded that
CAPOG was effective and was helping conusunicate managements' expectations
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,
supporting and monitoring the Corrective Action
Program
b) Corrective Action Program content, method and
implementation
c) Corrective Action Program overall effectiveness
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NSD930977
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Attachment ,
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Page 8 of 8
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3) An investigative team was formJd in July, 1993 to perfona an
independent assessment of enforcement issues identified in NRC !
Inspection Report 93-17. One of the objectives of this six member i
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team was to determine the adequacy of the proposed corrective
actions to the identified issues and to recommend additional actions ,
to prevent recurrence.
4) A performance assessment project was performed in late 1992 by an ;
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outside agency at the request of senior NPG management to.
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a) identify root causes of the lack of uniform performance
by District personnel
b) identify changes needed to raise levels of performance [
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up to managements' expectations
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c) provide recoassendations to effect thema changes
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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:
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1) Improving the process by making it more stream lined .
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i 2) Clarification and enforcement of ownership and accountability ;
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3) Improve communications at all levels to ensure all personnel
get the same message ;
, 4) Establish program performance monitoring including indicators.
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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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